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CITN 2020 SYLLABUS Page 1
THE CHARTERED INSTITUTE OF
TAXATION OF NIGERIA
NEW PROFESSIONAL
EXAMINATIONS SYLLABUS
-
EFFECTIVE DATE: APRIL 2021
CITN 2020 SYLLABUS Page 2
VISION
To be one of the foremost professional associations in Africa
and beyond
MISSION
To build an Institute which will be a citadel for the
advancement of taxation in all its ramifications
MOTTO
Integrity and Service
CITN 2020 SYLLABUS Page 3
CHAIRMAN’S STATEMENT
In this era of dynamic change affecting of all facets of business engagements, it is important that relevant
information is shared for day to day running of affairs.
Professional bodies charged with educating members and the public in professional matters cannot also
remain docile in the face of global stiff competition, hence the need to move with time.
The Chartered Institute of Taxation is aware of its role as spelt out in the Laws of the Federal Republic of
Nigeria and thereby taking a lead in Taxation as a Profession. The Syllabus of the Institute for educating
its members is always reviewed every five-year to address contemporary issues from time to time.
The current Syllabus will be expiring by the beginning of 2018 and will necessarily give way to a new one
now being proposed.
The New Syllabus is benchmarked along with all other relevant professional syllabi all over the world to
address salient developmental issues necessary for complete professional education. It is designed to make
a Total Tax Practitioner, Administrator and Educator by every definition of terms. The Issue of
*Professional Ethics driving global businesses today is given prominence in this syllabus. Besides, there
is
linkage between academic and professionalism to create a solid platform for Tax Education especially
where there is a need for one exemption or the other
The Council of this Institute is therefore happy to present this syllabus before all and for the use of all.
Professor Ishola Rufus AKINTOYE (FCTI-680)
BA (Accounting & FM, Sunderland-UK), BSc (Economics- Ghana), MBA (Accounting & Finance), MSc
(Finance), PhD (Accounting), PhD (Financial Management), FCA, FCTI, FNIM
*Professor of Accounting & Finance
*2017 ICAN Merit Awardee
*Chair, 1st CITN Professorial Chair of Taxation & Fiscal Policy
Chairman, Syllabus Review Committee, CITN
234-8035369293; 234-8072090181
CITN 2020 SYLLABUS Page 4
FOREWORD
The tax space is witnessing a major turnaround in the areas of policy, legislation, administration
and tax practice. As a dynamic profession consisting of multiple disciplines, its curriculum
must affirm its status as the melting point for the distillation and impartation of contemporary
thoughts shaping those strands of disciplines from which taxation has birthed. Council of the
Institute therefore learnt its weight behind this work by constituting the Syllabus Review
Committee.
The Institute has produced a slim, simple and concise revised syllabus with clear and distinct
subjects tailored towards affording Tax Professionals take on the onerous task of delivering an
efficient tax system for the mutual benefit of everyone.
It is gratifying to note the conversion policy which gives old students the opportunity to migrate
to the new syllabus while the newly registered students will commence from the new syllabus.
At the end of the examination and subsequent induction into the full fledge membership of the
Institute, the country would continue to be rest assured of possession of highly skilled and well
groomed manpower required to propel taxation, as a profession to the next level.
The Institute remains grateful to the members of the Syllabus Review Committee under the able
Chairmanship of Prof. Ishola Rufus Akintoye, FCTI, the first CITN Professorial Chair in
Taxation, at Babcock University, for the steadfastness and commitment to the given mandate,
inspite of the tight schedule. Contributions of other persons are also acknowledged including
Pastor Benjamin Omonayajo, Chairman, Examination Committee, Dr. Godwin Emmanuel
Oyedokun, Chairman, Education Committee and Dr. Titilayo Eni-itan Fowokan, Chairman,
Students and Tertiary Institutions Affairs Committee. Other resource persons who submitted
inputs to the Committee are also appreciated. This is to thank the staff of the Examination and
Students’ Affairs Department of the Institute headed by the Registrar/Chief Executive, Mr
Adefisayo Awogbade, FCTI for their hard work in ensuring that this project sees the light of the
day.
Chief (Dr) Cyril Ikemefuna Ede, FCTI
President/Chairman of Council
CITN 2020 SYLLABUS Page 5
MEMBERS OF THE SYLLABUS REVIEW COMMITTEE
S/N NAMES STATUS DESIGNATION
1.
Prof. Ishola Rufus Akintoye
Chairman
Accounting Department, Babcock
University/CITN Professorial Chairperson
2.
Pastor Benjamin Omonayajo
Member
Council Member, Chairman, Examination
Committee
3. Dr. Godwin Emmanuel
Oyedokun
Member Council Member, Chairman, Education
Committee, Vice Chairman, Examination
Committee
4.
Dr. (Mrs.) Titilayo Eni-Itan
Fowokan
Member Council Member, Chairman, Students’ Affairs
Committee
5. Prof. Rafiu Oyesola Salawu Member Accounting Department, Obafemi Awolowo
University, Ile-Ife
6. Mr. Taiwo Oyedele Member Partner/Head of Tax PwC
7. Mrs. Junila Nneka Takon Member Director, Human Capital, FIRS
8. Barr. Rasaq. O Bello Member Vice Chairman I, Examination Committee
9. Mrs. Ojuolape Fajuyitan Member Vice Chairman II, Examination Committee
10. Mrs. Sandra Momah Member Associate Director, International Tax & Service,
Ernst & Young
11. Mr. Martins Arogie Member Senior Manager, Tax & Regulatory, KPMG
12.
Mrs. Asiata Agboluaje Member Senior Manager, Tax & Regulatory, Deloitte
13. Mr. Igho Otejiri Orienru Member Assistant Director, Head, Staff Training School,
LIRS
14. Mr. Kenneth Erikume Member Partner, PwC
15. Dr. Olusola John Dada Member Lecturer, Accounting & Finance Department,
McPherson University
16. Mrs. Oyeronke Ojo CITN Assistant Director, (Head) Examination &
Students’ Affairs Department, CITN
17 Mr. Ayodeji Adeyemi CITN Deputy Manager, Examination & Students’
Affairs Department, CITN
18 Mrs. Adeola Oyefeso CITN Assistant Manager, Examination & Students’
Affairs Department, CITN
CITN 2020 SYLLABUS Page 6
PROFESSIONAL EXAMINATION SYLLABUS
INTRODUCTION
The Chartered Institute of Taxation of Nigeria started on February 4, 1982 as Association of Tax
Administrators and Practitioners. Thereafter, it metamorphosed into Nigerian Institute of Taxation, which
was formally launched on February 21, 1982 and statutorily recognized on May 6, 1987 as a Company
Limited by Guarantee. The Institute was chartered by the Federal Government of Nigeria through Decree
number 76 of 1992 and was charged with the duty, among others of determining what standards of
knowledge and skill are to be attained by persons seeking to become its members. Membership of the
Institute cuts across such professions like Accounting, Law and other professionals who have acquired
relevant tax experience.
AIMS AND OBJECTIVES
The aims and objectives of the Institute as laid down in its enabling Act are, among others, as follows:
i. To raise, maintained and regulate the standard of taxation practice amongst its members.
ii. To promote professional ethics and efficiency in tax administration and practice.
iii. To encourage, promote and co-ordinate research for the advancement of taxation in Nigeria.
MEMBERSHIP
There are two main classes of membership of the Institute at the moment. These are Fellows and
Associates.
FELLOWS
Associates who wish to advance to fellowship may do so by submitting an acceptable these and then
satisfying the council that his/her work has been closely connected with and of direct relevance to Nigeria
Taxation for an unbroken period of at least five (5) years prior to such application as fellow. In the
alternative, a total qualifying period of at least five (5) years prior to such application may be considered
if it falls within a period not exceeding ten (10) years immediately prior to such application for admission
as a fellow.
ASSOCIATE MEMBERS
In accordance with the Charter and Rules and Regulations of the Institute, a person is admitted as an
associate member on application, if he/she is a graduate member of the Institute and has acquired the
relevant tax experience or has completed any of the recognized examinations of the Institute. Members
of other professional bodies are admitted after they have served a specific period either in tax practice
and administration.
DESIGNATORY LETTERS
CITN 2020 SYLLABUS Page 7
Every member of the Institute having been admitted at appropriate level is entitled to use the following
designatory letters after his/her name.
ACTI – Representing Associate Member of the Chartered Institute of Taxation of Nigeria.
FCTI – Representing Fellow of the Chartered Institute of Taxation of Nigeria.
MEMBERSHIP, FEES AND SUBSCRIPTION
Admission fees and annual subscription are payable by each member in accordance with the Rules and
Regulations.
ADDRESS OF THE SECRETARIAT
The Chartered Institute of Taxation of Nigeria
Tax Professionals’ House
Plot 16, Otunba Jobi Fele way,
CBD, Alausa Ikeja
P.O. Box 1087, Ebute-Metta,
Lagos State, Nigeria.
Tel: 09080888815
E-mail: [email protected].
Website: www.citn.org
ABUJA LIASON OFFICE
David Ajibola Olorunleke’s House
Block 26 (27), Abidjan Street, Wuse Zone 3,
Abuja, FCT, Nigeria
Tel: (234) 09-2918349
E-mail: [email protected],
Website: www.citn.org
For more information about the syllabus, please contact:
Mr. Adefisayo Awogbade, FCTI
Registrar/Chief Executive
E-mail: [email protected].
CITN 2020 SYLLABUS Page 8
ENTRY REGULATIONS AND REGISTRATION
A. REGISTRATION PROCEDURE:
Application for admission to student membership must be made on the prescribed form. This requires an
undertaking on the part of the applicant to abide by the rules laid down by the Council from time to time.
The procedure as stipulated below:
All forms for Application have to be filled online (www.citn.org/join_citn)
This information is by the order of the Council of the Chartered Institute of Taxation of Nigeria. For
further enquiries, please, contact the Examinations and Students’ Affairs Department of the Institute on
[email protected] or [email protected]
Every applicant shall produce satisfactory evidence of age, name, character and eligibility together with
photocopies of his/her educational certificates. The Council reserves the right to grant or refuse any
application or to terminate the registration of a candidate. A successful applicant shall be required to pay
the prescribed registration and annual subscription fees for the year; upon which he shall be allocated a
student number. This number must be quoted in full in all communications with the Institute.
B. CONDITIONS TO BE SATISFIED
Every prospective candidate for admission to student membership must satisfy the Council that:
• He possesses the basic minimum educational qualification as set by Council.
• He is a fit and proper person to be registered.
Any student failing to comply with the above regulations may be liable for such penalties as the Institute
may decide
C. ELIGIBILTY TO REGISTER
An applicant shall be eligible to register as a student if he/she possesses a minimum of:
• First degree, Higher National Diploma or its equivalent.
• Undergraduates with evidence of admission into higher institutions
EXAMINATIONS
1. Eligibility to Register for the Examination.
Entry for the Institute’s Examinations is open to all registered student members of the Institute. A registered
student member is however expected to have paid the regular annual subscription and entry fees in force at
the date of entry.
CITN 2020 SYLLABUS Page 9
2. EXAMINATION RESULTS AND CREDIT SYSTEM
The new credit system stipulates that candidates can sit for any number of paper up to four at a particular
level. However, a candidate must finish a level before proceeding to another. That candidate must pass
minimum of one (1) paper out of the four papers. Candidate will be credited with the paper(s) previously
passed. There will be opportunity to re-write the remaining papers at subsequent examinations subject to
limited period. Candidate writing the Professional Examinations would have a maximum of eight (8) years
to pass all levels of examinations within which candidate will be credited with earlier passed papers, but start
afresh if unable to satisfy this condition within the specified period. Any candidate who passes one paper out
of all the papers written should be credited with that paper subject to the provision that the candidate must
apply to sit for all papers he/she would have been eligible to participate in the diet. On completion of
examination, candidate must has fulfilled a total credit requirement of 36units.
3. EXAMINATION STRUCTURE- STUDENT ASSESSMENT
FOUNDATION:
SECTION A Multiple Choice Question - 20 Questions - 1 mark each
Short Answers - 10 Questions - 1 marks each
Sub – Total 30 marks
SECTION B Theory
Question 1 is compulsory with 25 marks 25 marks
Answer 3 questions out of 5 with 15 marks each 45 marks
Sub – Total 70 marks
Overall Total 100 marks
PROFESSIONAL TAXATION I
Question 1 is compulsory with 40 marks 40 marks
Answer 4 questions out of 6 with 15 marks each 60 marks
Overall Total 100 marks
PROFESSIONAL TAXATION II
Question 1 is compulsory with 40 marks 40 marks
Answer 4 questions out of 6 with 15 marks each 60 marks
Overall Total 100 marks
The Institute shall introduce Computer Based Test (CBT), which will be a phased project commencing in the
year 2020.
CITN 2020 SYLLABUS Page 10
4. NEW EXEMPTION FEE
1. Foundation
Exemption form fee 4,000.00
Per Subject Fees 7,000.00
2. Professional Taxation 1
Exemption form fee 4,000.00
Per Subject Fees 9,000.00
3. Professional Taxation 2
Exemption form fee 4,000.00
Per Subject Fees 10,000.00
5. NEW EXAMININATION FEE
1. Foundation
Examination Form Fee 1,000.00
Registration Fees (Non Refundable) 8,000.00
Per Subject Fees 7,000.00
Total Subject Fees (4 Papers) 28,000.00
Study Material/Per Subject Fees 1,500.00
2. Professional Taxation 1
Examination Form Fee 1,000.00
Registration Fees (Non Refundable) 10,000.00
Per Subject Fees 9,000.00
Total Subject Fees (4 Papers) 36,000.00
Study Material/Per Subject Fees 1,500.00
3. Professional Taxation 2
Examination Form Fee 1,000.00
Registration Fees (Non Refundable) 12,000.00
Per Subject Fees 10,000.00
Total Subject Fees (4 Papers) 40,000.00
Study Material/Per Subject Fees 1,500.00
CITN 2020 SYLLABUS Page 11
6. CONVERSION
Since a credit system will be in operation when the new syllabus takes off, candidates who are unable to
complete the examinations before the take-off date would only be credited with the relevant subjects/courses
already passed in the old syllabus.
Candidates that failed any subject in the old syllabus will be required to write the stated subjects in the new
syllabus as itemized below:
S/N OLD SYLLABUS NEW SYLLABUS
Subjects to be written by candidates who failed any of the
subjects in the old syllabus
FOUNDATION FOUNDATION
1. Principles of Taxation Principles of Taxation
2. Accounting Financial Accounting
3. General Principles of Law Business Law
4. Economics Economics
PROFESSIONAL TAXATION I PROFESSIONAL TAXATION I
1. Quantitative Techniques Financial Reporting and Governance, Risks & Ethics
2. Revenue Law Financial Reporting and Governance, Risks & Ethics
3. Income Taxation Income Taxation, Financial Reporting and Governance, Risks
& Ethics
4. Indirect Taxation Indirect Taxation, Financial Reporting and Governance, Risks
& Ethics
PROFESSIONAL TAXATION II PROFESSIONAL TAXATION II
1 Taxation of E-commerce Taxation of E-commerce (repeat until you pass), Financial/Tax
Analysis & Income Tax for Specialized Businesses.
2. Strategy, Risk and Ethics Governance, Risk & Ethics, Financial/Tax Analysis & Income
Tax for Specialized Businesses.
3. Tax Audit and Investigation Tax Audit and Investigation, Financial/Tax Analysis &
Income Tax for Specialized Businesses.
4. International Taxation International Taxation, Financial/Tax Analysis & Income Tax
for Specialized Businesses.
PROFESSIONAL TAXATION III
1 Oil, Gas Taxation Income Tax for Specialized Businesses in PT II
2 Solid Minerals Taxation Income Tax for Specialized Businesses in PT II
3. Tax Management Financial/Tax Analysis
4. Practical Cases in Taxation Financial/Tax Analysis
CITN 2020 SYLLABUS Page 12
7. EXEMPTION
S/N
QUALIFICATION
EXEMPTION (NEW)
1.
TTS Graduates,
(ATT)/ATS/ATSWA, OND
(Accounting &Taxation)
All Foundation Papers
2.
ICAN(ACA)
All Foundation Papers, All PT I papers & PT II papers except Income Tax for
Specialized Businesses
3.
ANAN(CNA)
All Foundation Papers, All PT I papers & PT II papers except Income Tax for
Specialized Businesses
4. BL
All Foundation Papers, All PT I papers & PT II papers except Financial/Tax
Analysis and Income Tax for Specialized Businesses
5. ACCA All subjects at all levels except Business Laws, Income Tax for Specialized
Businesses
6. CIOT All subjects at all levels except Business Laws, Income Tax for Specialized
Businesses
7. CITN TAX ACADEMY (CTA) Subject by subject exemption
8.
CIMA All subjects at all levels except Business Laws, Income Tax for Specialized
Businesses
9.
ACIB
All Foundation Papers, Financial Reporting and Governance, Risk & Ethics
in PT I
10.
ACS/ACIS/ICSAN
All Foundation Papers, Financial Reporting, and Financial/Tax Analysis in
PT II
11.
MNIM
All Foundation Papers, Governance, Risk & Ethics, and Financial Reporting
in PT I
12. LLB All Foundation Papers, All PT 1 Papers
13.
HND/Degree Taxation
All Foundation Papers, All Papers in PT 1 and International Tax, and Tax
Audit & Investigation in PT II
14.
HND/Degree (Accounting)
All Foundation Papers, All PT 1 Papers
15. HND/Degree
Banking/Finance/Insurance
All Foundation Papers, All PT 1 Papers
16.
Degree in Economics
All Foundation Papers, All PT 1 Papers
CITN 2020 SYLLABUS Page 13
17.
HND/Degree
Bus. Admin/Public Admin/Bus
Management
All Foundation Papers, except Principles of Taxation, and Financial
Reporting & Governance, Risk Ethics in PT 1 Papers
18. HND/Degree Maths/Statistics Economics in Foundation and Financial Reporting in PT I
19. Other Degrees not stated here Subject by subject exemption upon presentation of transcript
20. Masters in Management Sciences
with Taxation Option/Taxation
course in Transcript
All papers in Foundation, all papers in PT I, International Taxation and
Financial/Tax Analysis in PT II
21.
Masters’ Degree in Management
Sciences
All papers in Foundation, all papers in PT I
22.
All other Masters’ Degree Subject by subject exemptions upon presentation of transcript
23. PhD in Management Sciences with
Taxation Option/Taxation course in
Transcript
All papers in foundation, all papers in PT I, all papers in PT II except Income
Tax for Specialized Businesses
24.
PhD Degree in Management
Sciences
All papers in foundation, all papers in PT I, all papers in PT II except Tax
Audit & Investigation and Income Tax for Specialized Businesses
25. All other Doctoral Degrees in
Management Sciences
All papers in foundation, all papers in PT I, except Tax Audit & Investigation
and Income Tax for Specialized Businesses
26. All other Doctoral Degrees Subject by subject exemptions upon presentation of transcript
27. FIRS/JTB Fundamental Level Principle of Taxation in Foundation
28. FIRS/JTB Preliminary Level All Papers in Foundation, all papers in PT I and International taxation in PT
II
29. FIRS/JTB Final Level All papers in foundation, all papers in PT I, all papers in PT II except
Financial/Tax Analysis
30. All other Professional Certificates Subject by subject exemptions upon presentation of certificate
CITN 2020 SYLLABUS Page 14
For all categories of exemptions, having only two subjects, without prejudice to the level can be combined
within a diet, as far as the examination timetable does not clash.
8. Commencement Date of the new Syllabus
This new syllabus will take effect for new students from April 2020.
9. Absence from and Misconduct in an Examination
Examination entries cannot be withdrawn after the closing date for any reason whatsoever. Consequently, if a
candidate decides not to attend or is unable to attend the examination, fees paid for the examination will not be
returned or transferred to subsequent examinations. Any misconduct in an examination shall be referred to the
Institute’s Disciplinary Committee for necessary investigation and appropriate sanction.
Disciplinary actions as prescribed by the Council of the Institute will be taken against any candidate found guilty
of Examination Malpractice or Misconduct.
The identity of candidate found guilty of either Examination Malpractice or Misconduct, the offence and
disciplinary action meted against him/her will be published in the Institute’s journal - Nigerian Taxation, CITN
Newsletter and in some Daily Newspapers.
Such disciplinary actions include one or combinations of the following:
i. Cancellation of results of the affected candidate;
ii. Suspension of the affected candidate from the Institute’s examination for one or more
diets;
iii. Blacklisting, in which case, the affected candidate will be banned from the Institute’s
examinations indefinitely;
iv. Reporting the affected candidate to the member who sponsored the entry form for the
examination;
v. Reporting the affected candidate to his/her employer or guardians;
vi. De-registration of the candidate;
vii. Handing over the candidate to the law enforcement agents like Police;
viii. Publishing the identity of the candidate, the offence and disciplinary actions in the
Institute’s journal, CITN Newsletter, newspapers, etc.
CITN 2020 SYLLABUS Page 15
DETAILS OF MALPRACTICES AND PENALTIES
S/N Malpractice Penalties
1 Receiving or giving assistance from or to
another candidate on matters relating to the
paper during the course of the examination
i. Cancellation of that particular
paper
ii. Cancellation of all papers of
candidate for the particular
examination
iii. Suspension for two diets.
2 Receiving or giving assistance not
necessarily relating to the examination
without permission
Cancellation of score relating to
the particular paper
3 Copying from another candidate without
the candidate’s knowledge
i. Cancellation of all papers of
candidate for the particular
examination
ii. Suspension for two diets
4 Receiving assistance from invigilators on
matters relating to the examination
i. Cancellation of that
particular paper
ii. Invigilator to be referred to
the Investigating panel
5 Taking away answer script i. Written warning
ii. Cancellation of that
particular paper
6 Being rude to the Invigilator as a first
offender
Written warning
7 Presentation of forged certificate/document
to register for or write the examination
Blacklisting of the candidate
CITN 2020 SYLLABUS Page 16
NEW PROFESSIONAL SYLLABUS
I. Foundation:
• Principles of Taxation
• Financial Accounting
• Business Law
• Economics
II. Professional Taxation I:
• Financial Reporting
• Income Tax
• Indirect Tax
• Governance, Risk & Ethics
III. Professional Taxation II
• Tax Audit and Investigation
• International Taxation
• Financial / Tax Analysis
• Income Tax for Specialized Businesses
OLD PROFESSIONAL LEVEL
I. Foundation
• Principles of Taxation
• Accounting
• General Principles of Law
• Economics
II. Professional Taxation I
• Quantitative Techniques
• Income Taxation
• Indirect Taxation
• Revenue Law
III. Professional Taxation II
• Tax Audit & Investigation
• International Taxation
• Taxation of E-commerce
• Strategy, Risk, Ethics
IV. Professional Taxation III
• Oil, Gas Taxation
• Solid Minerals Taxation
• Tax Management
• Practical Cases
CITN 2020 SYLLABUS Page 17
FOUNDATION
COURSE TITLE: PRINCIPLES OF TAXATION
Course Description:
This course is designed to introduce students to Taxation within the Nigerian context. It teaches students the fundamental
principles of taxation to enable them to appreciate the course right from its meaning to how the Nigerian tax system
operates. The focus of this course is to expose students to the basic knowledge and application of tax legislation to enable
them to have better comprehension of other courses in taxation.
Prerequisites: Standard qualification requirements as approved by the Institute
Aims and Objectives of the Course:
At the end of this paper, candidates will be able to:
i. Define tax and taxation; list the objectives and characteristics of taxation;
ii. Explain the legislative framework of taxation;
iii. Discuss theories of taxation and list types of taxes;
iv. Describe the concepts of Nigeria tax system-tax policy, tax laws and tax administration; and
v. Explain commonly used terms, other related fundamental concepts and principles of taxation required at an
introductory level.
1. AN OVERVIEW OF TAXATION
• The Concept of Taxation
i. Definition/Meaning of Tax and Taxation
ii. The Difference between Tax and Other Charges
iii. Justification for Taxation as the most Reliable Source of Revenue to Government
• History of Taxation
i. Origin of Taxation
ii. Taxation in Nigeria: Colonial Era
iii. Taxation in Nigeria: Post Independence Era to Date
• Legislative Framework
i. Enabling Acts
ii. Sources of the tax laws in Nigeria
• Objectives of Taxation
i. Some of the purposes for which Government spends money
• Types of Taxes
i. Direct Tax
ii. Indirect Tax
• Classification of Tax
CITN 2020 SYLLABUS Page 18
i. By Tax Base
ii. By Tax Incidence
iii. By Method-Proportional, Progressive, and Regressive
• Characteristics/Qualities of a Good Tax
i. Equity and Justice; Convenience; Certainty; Administrative Efficiency; Neutrality; Flexibility;
Impartiality; Simplicity
2. THE NIGERIAN TAX SYSTEM
• The Relationship between Tax Policy, Tax Law and Tax Administration
i. The National Tax Policy
• Nigerian Tax Administration:
i. The Joint Tax Board
ii. Federal Inland Revenue Service
iii. State Board of Internal Revenue
iv. Local Government Revenue Committee
3. OTHER FUNDAMENTAL CONCEPTS/PRINCIPLES
i. Tax Appeal Tribunal
ii. Tax Reforms
iii. Tests of Trade
iv. Definition of Employment
v. Differences between Employment and Engagement on contract
vi. Measurement of Income
vii. Revenue Income/Expenses, Capital Income/Expense
viii. Pioneer Status and other Tax incentives
READING TEXTS: Textbooks/Journals and Others
Federal Government of Nigeria - National Tax Policy 2012/2017
Gboyega Adejuwon -Analysis of Taxation Principles for Nigerian Students Vol. 1
Joseph Ajibola Arogundade (2016) -Nigerian Income Tax & International Dimension
Spectrum Book Limited.
Lekan Soyode & Sunday Kajola - Taxation Principles and Practice in Nigeria
Offiong U. Bassey(2013) -Company Taxation in Nigeria.
CIBN Press
Obatola S. Olugbenga - The Rudiments of Nigerian Taxation
Ogundele E. Afe - Elements of Taxation
Oni, I. O. - Nigerian Companies Income Tax: Law & Practice
Ochei, B. B. - The Nigerian Taxman’s Book
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.
Vol. I &II
CITN - Tax Guide and Statutes
CITN - Tax Series
CITN 2020 SYLLABUS Page 19
COURSE TITLE: FINANCIAL ACCOUNTING
Aims and Objectives of the Course:
At the end of this paper, candidates will be able to:
i. Knowledge and understanding and application of the fundamental principles, processes, concepts,
conventions and regulatory framework employed in preparing financial statements;
ii. Proficiency in double-entry accounting techniques and maintenance of accounting records;
iii. Ability to identify and correct omissions and errors in accounting records and financial statements;
iv. Ability to prepare financial statements of sole traders, not-for-profit organizations, partnerships
(including admissions, dissolutions, amalgamations and absorption) and limited liability companies
using basic accounting principles and relevant accounting standards;
v. Awareness of various accounting techniques and their uses;
vi. Ability to analyze and interpret simple accounts with aid of financial ratios.
COURSE CONTENTS
1. INTRODUCTION TO BUSINESS AND ACCOUNTING
i. Types of business
ii. Introduction to financial accounting by business entities
iii. Bases of accounting
iv. The need for financial statements
v. The components of financial statements
vi. Business transactions
2. THE IASB’S CONCEPTUAL FRAMEWORK
i. A conceptual framework for financial reporting
ii. The IASB Conceptual Framework
iii. Qualitative characteristics of useful financial information
iv. The elements of financial statements
v. Recognition in financial statements: IASB Conceptual Framework
vi. Other accounting concepts
vii. Fair presentation
3. ACCOUNTING EQUATION
i. The accounting equation
ii. Preparing a simple statement of financial position
iii. Statement of profit or loss
4. DOUBLE ENTRY BOOKKEEPING
i. Introduction to accounting systems
ii. Basic rules of double-entry bookkeeping
iii. Account balances and the trial balance
iv. General journal
CITN 2020 SYLLABUS Page 20
v. General ledger
5. SALES AND PURCHASES
i. Introduction to books of prime entry
ii. Accounting for sales
iii. Accounting for purchases
iv. Accounting for cash
v. Petty cash
6. NON-CURRENT ASSETS AND DEPRECIATION
i. End of year adjustments
ii. Non-current assets
iii. Depreciation and carrying amount
iv. Methods of charging depreciation
v. Derecognition of property, plant and equipment
vi. Disclosure requirements of IAS 16
7. BAD AND DOUBTFUL DEBTS
i. Bad debts
ii. Doubtful debts
8. ACCRUALS AND PREPAYMENTS
i. Accruals and prepayments introduced
ii. Accruals
iii. Prepayments
iv. Unearned and accrued income
9. INVENTORY
i. End-of-year adjustments for inventory
ii. Measurement of inventory
10. CONTROL ACCOUNTS AND CONTROL ACCOUNT RECONCILIATIONS
i. Receivables control accounts and receivables control account reconciliations
ii. Payables control accounts and payables control account reconciliations
iii. Supplier statements: reconciliation with ledger account
11. BANK RECONCILIATIONS
i. Bank reconciliations
ii. Chapter review
12. CORRECTION OF ERRORS
i. Trial balance
ii. Correcting errors
iii. Suspense accounts
13. COMPANY FINANCIAL STATEMENTS
CITN 2020 SYLLABUS Page 21
i. The components of financial statements
ii. Structure and content of the statement of financial position
iii. Structure and content of the statement of profit or loss
iv. Accounting for taxation
v. Accounting for share issues
vi. Financial statements – specimen formats
14. PARTNERSHIP ACCOUNTS
i. Features of partnerships
ii. Sharing the profits between the partners
iii. Changes in partnerships
iv. Amalgamation and dissolution of partnerships
15. NOT FOR PROFIT ACCOUNTS
i. Not for profit organizations
ii. Receipt and payment accounts
iii. Income and expenditure account
16. CONCEPT OF ACCOUNTS FROM INCOMPLETE RECORDS
i. The nature of incomplete records
ii. Techniques for incomplete records
17. STATEMENTS OF CASH FLOW
i. Statement of cash flows: Introduction
ii. Statement of cash flows: Format
iii. Cash flows from operating activities: The indirect method
iv. Indirect method: Adjustments for working capital
v. Cash flows from operating activities: The direct method
vi. Cash flows from investing activities
vii. Cash flows from financing activities
viii. Statement of cash flows – specimen formats
RECOMMENDED TEXTBOOKS:
Akeju J. B - Financial Accounting (Volume I & II) – JBA Associates
Limited Lagos.
Anao A.R. - An Introduction to Financial Accounting, Longman.
Danjuma Zubairu - Modern Financial Accounting
Frank Wood - Business Accounting I & II (Financial Times, London) IASB – International
Financial Reporting Standards.
Ifede A. I - Fundamentals and Practice of Financial Accounting (Gondolier I. Ventures)
IFRS - Statements of Accounting Standards (Relevant IFRS)
Igben R.O. - Financial Accounting made simple (Volume I & II) ROI Publishers Lagos.
CITN 2020 SYLLABUS Page 22
Jennings, A. (2015) - Financial Accounting, I & II (MCgraw Hill)
Mainoma M.A. & Adebayo P.A. - Financial Reporting Standards: Comparative Synthesis
Soyode A. - Accounting (Graham Burn). Spicer & Pegler -Book- keeping & Accounting.
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.Vol. I &II
CITN - Tax Guide and Statutes
CITN Study Pack on Accounting
ICAN Study Pack on Accounting
CITN 2020 SYLLABUS Page 23
COURSE TITLE: BUSINESS LAW
Course Description:
Taxation is based on law, thus it is important to understand the fundamentals of law, the legal system and how
it operates. This course is aimed at introducing candidates to diverse types of laws that relate to business and its
taxation, ranging from law of contract, sale of goods, agency law, company law, intellectual property law,
employment law, revenue law and other relevant laws.
Aims and Objectives of the Course:
The purpose of this course is to examine candidates’ knowledge and understanding of the general principles of
Law with particular reference to Nigerian legal and tax system and basic principles regulating business
transactions.
Candidates are expected to be able to identify and apply the elements of contracts, applicable legal principles to
different types of transactions and how they may be impacted by taxes. The course also seeks to introduce
candidates to revenue laws in Nigeria, modalities for interpretation and administration as well as overview of the
available dispute resolution mechanisms.
It prepares candidates for subsequent courses. It is considered prerequisites for the following courses: Practice
of Income & Indirect Taxation, Income Tax for Specialized Businesses, International Taxation as well as Tax
Audit & Investigation. It also enhances ability to provide practical advice upon becoming a chartered tax
practitioner.
COURSE CONTENTS
A. INTRODUCTION TO NIGERIAN LEGAL SYSTEM & REVENUE LAW
1. Nigerian Legal and Court System
i. The definition of law and distinction between its validity and efficacy
ii. Nature and functions of Law
iii. The distinction between criminal law and civil law
iv. Nigerian legal system and administration of law
v. Separation of Powers - Legislature, Executive and Judiciary – and their functions
vi. Sources of Nigerian law- Received English Law, Local legislation and International law regulating
business; conflict of laws
vii. Alternative dispute resolution mechanisms
viii. Hierarchy of courts in Nigeria
• National Industrial Court
• Investments and Securities Tribunal and other Tribunals
• Tax Appeal Tribunals
CITN 2020 SYLLABUS Page 24
• High Court and Federal High Court (FHC) (exclusive jurisdiction of the FHC
• Court of Appeal
• Supreme Court
ix. The merits and demerits of court-based adjudication and alternative dispute resolution
mechanisms
2. International law application to commercial transactions
a) Application of international law (treaties, conventions, protocols) and conflict of laws
b) The roles of international organisations (UN, ICC, WTO, OECD, UNIDROIT, UNCITRAL in
international trade
c) Application of UN Convention on Contracts for International Sale of Goods and ICC Incoterms
3. Revenue law
a) Overview of tax system, power to make tax laws, and constitution of taxing rights, quasi–laws,
circulars, guidelines etc.
b) Introduction to tax statutes/Categories of taxation
i. Income Tax
• Companies Income Tax Act
• Personal Income Tax Act
• Petroleum Profit Tax Act
• Tertiary Education Tax Act
ii. Capital Gains Tax Act
iii. Indirect taxation/transaction taxes
• Value Added Tax Act
• Stamp Duties Act
• Customs and Excise Management Act
c) Overview of Finance Act 2020 – Amendments to
• Companies Income Tax Act (sections 9,10,13, 16,19,including increased monetary penalty for
late filing of tax returns)
• Capital Gains Tax Act
• Personal Income Tax Act (section 49)
• Value Added Tax (sections 4,8 and 15)
• Stamp Duties Act
• Petroleum Profits Tax Act (section 20)
d) Special tax incentives
i.Industrial Development (Income Tax Relief) Act
ii.Nigeria Export Processing Zones Act
e) Interpretation of tax laws
f) Tax administration authorities in Nigeria
CITN 2020 SYLLABUS Page 25
i. Federal Inland Revenue Service
ii. State Inland Revenue Service
iii. Joint Tax Board
iv. Local Government Revenue Committee
B. LAW OF CONTRACT
o Formation and formalities of contract
o Major types of contract and effect
o Elements of a valid contract
o Capacity to contract
o Terms of a contract
o Vitiating factors
o Discharge of contract
o Remedies for breach of contract
C. ECONOMIC TORTS
1. Classification of torts
2. Liability for torts in general and exemption from liability
3. Negligence
4. Occupiers liability
5. Product liability
6. Vicarious liability
7. Passing off
D. AGENCY
1. Agency and its types
2. Relationship between principal and agent – rights and duties
3. Implication of agency relationship
4. Termination
E. COMMERCIAL TRANSACTIONS
1. Sale of goods
a) Domestic Laws and Introduction to the UN Convention on Contracts for the International Sale of Goods
and ICC Incoterms
b) Sale, conditional sale and protection of consumers
c) Passing of ownership and risk
CITN 2020 SYLLABUS Page 26
d) Conditions, warranties and exclusion clauses
e) Transportation of goods, duties and liability of carriers
f) Delivery of the goods and highlights of various Incoterms (Free on Board (FOB), Duty Delivery
Paid, Cost, Insurance & Freight (CIF) etc.)
g) Duties, rights and remedies of buyer and seller
4. Consumer Credit transactions (hire purchase, credit sales, and leasing)
a) Characteristics of hire purchase
b) Rights and duties of parties under hire purchase
c) Credit sales and duties of parties
d) Types of leasing and obligations of parties
F. BUSINESS ORGANISATIONS AND THEIR FORMATION
1. Nature and types of business organisation
a) Sole Proprietorship
b) Partnership (including Limited Liability Partnership (LLP) and business name registration
i. Types and formation of partnership
ii. Relationship of partners with one another and with third party
iii. Rights and duties of partners
iv. Termination of partnership and partner’s rights and liabilities on dissolution
c) Companies
i. Formation of companies and consequences of incorporation
ii. Lifting the veil of incorporation
iii. Promoters – duties, breach and remedies
iv. Raising of capital – equity (share) and loan (fixed income) capital
v. Maintenance (including payment of dividends), Increase and reduction of capital
vi. Creation and registration of charges
vii. Appointment, remuneration and removal of directors
viii. Company directors and their duties
ix. Other officers of the company – company secretary and auditors – appointment, rights,
duties, and removal
x. Company meetings and resolutions
xi. Corporate insolvency
xii. Corporate Restructuring – mergers, acquisition, etc.
xiii. Winding up of the company
CITN 2020 SYLLABUS Page 27
2. Insider dealing, market manipulation and corporate governance
a) The nature and penalty for insider dealing under the Investments and Securities Act
b) Other forms of securities market manipulation
c) Risk management and basic corporate and internal controls
RECOMMENDED TEXTS
Ade Ipaye Nigeria Tax Law and Administration
Ayua, I.A.
Nigerian Tax
Abdulrazaq, M.T Nigerian Revenue Law
Abdulrazaq M.T.
Abiola Sanni
Revenue Law and Practice in Nigeria
Revenue Law (CITN) Series
Bolaji Alabi
Obilade
Business Law in Nigeria
Nigeria Legal System
Sulu, E.A Nigerian Tax Cases (ES Business Ltd)
Itse Sagay Law of Contract
George Etomi (2014) An Introduction to Commercial Law in Nigeria
CITN Tax Guide and Statutes
Teju Somori - TejuTax Reference Book. 2012 Edition.Vol. I &II
Yemi Oke - Nigerian Energy and Natural Resources Law
M. O. Adesanya - Business Law in Nigeria
CITN Study Pack on Business Law
ICAN Study Pack on Business Law
Companies and Allied Matters Act 2020
Federal Competition and Consumer Protection Act 2019
Investments and Securities Act 2007
Nigerian Code of Corporate Governance 2018
ICAN Study Pack on Business Law
CITN 2020 SYLLABUS Page 28
COURSE TITLE: ECONOMICS
Aims and Objectives of the Course:
The aim and objective is to examine the candidate’s knowledge and understanding of the basic economic
principles and main features of Nigerian economic system. Also to intimate the students with the basic concepts
of microeconomics and macroeconomics policies; and how they are applied in the real world.
COURSE CONTENTS
PART1: MICROECONOMICS
1. NATURE AND MEANING OF ECONOMICS
i. Fundamental concepts – Meaning of economics, Scarcity, choice, scale of preference and
opportunity cost
ii. Economic models and Economic methods
iii. Microeconomics and macroeconomics
iv. Economic system- Central problems of an economy
v. Production possibility curve and Resources allocation
vi. Types and resources allocation under different economic system (Free market economy,
centrally controlled economy, mixed economy)
2. PRICE SYSTEM
i. Functions of price and price mechanism
ii. Theory of Demand-Meaning, laws, types, determinants, exceptions, change and shift in demand
iii. Theory of Supply-Meaning, laws, types, determinants, exceptions, change and shift in supply
iv. Equilibrium and disequilibrium in demand and supply
v. Elasticity of demand and supply, types (price, income and cross elasticity) and their calculations
vi. Elasticity of demand and supply and tax incidence
vii. Factors affecting elasticity of demand and supply
viii. Government Intervention through price control and its effects.
3. CONSUMER BEHAVIOUR
i. The basis of consumer demand–Utility
ii. Cardinal utility theory and ordinal utility and their assumptions, utility maximization
iii. Indifference curves theory
iv. Characteristics of Indifference curve
v. Total and marginal utility concepts
vi. The law of diminishing marginal utility
vii. Consumer surplus
CITN 2020 SYLLABUS Page 29
4. PRODUCTION AND COSTS
i. Factors of production and their rewards
ii. Production functions
iii. The law of diminishing returns-Total product (TP). Average product (AP) and Marginal product
(MP)
iv. Isoquant and Isocost curves
v. Pricing of factors of production
vi. Theory of cost – Opportunity cost, sunk costs, explicit and implicit costs, short run and long run
concept
vii. Total cost, fixed cost, variable cost, average cost and marginal cost
viii. Concept of revenue- Total, average and marginal revenue
ix. Cost minimization and profit maximization.
5. THEORY OF FIRMS AND LOCATION OF INDUSTRY
i. Concepts of firm, industry and market
ii. The goals of the firms
iii. Market structure: Characteristics, pricing and output decision under the following
markets- Perfect competition, monopoly, monopolistic and oligopoly
iv. Profit maximization and cost maximization
v. Price discrimination under monopoly
vi. Location of industry – Reasons, advantages and problems of industrialization in Nigeria
vii. Localization of industry – Industrial concentration- advantages and disadvantages
viii. Industrial promotion policy in Nigeria
ix. Privatization, commercialization, mergers, e-Commerce and firms’ acquisition policy in
Nigeria.
PART 2: MACROECONOMICS
1. NATIONAL INCOME ANALYSIS
i. Meaning of Macroeconomics
ii. Definition of national income
iii. The circular flow of Income
iv. Basic concepts of national income- Flow variable, Stock variable, Model, Variables, Gross
Domestic Product (GDP), Gross National Product (GNP), Net National Product (NNP), Personal
income, Disposable income, Per capita income etc
v. Methods of measuring national income: Expenditure Approach, Income Approach and Output
Approach
vi. Difficulties in measuring national income
vii. Factors influencing the national income
viii. Uses of national income accounting
ix. Limitations of National Income in International and Intertemporal Comparison
x. Reasons for differences in the National Income of different countries
xi. Aggregate Demand/Supply: Consumption, Investment, Government expenditure, Export and
CITN 2020 SYLLABUS Page 30
Import, Aggregate supply, Saving, Marginal Propensity to consume and to save etc.
xii. The accelerator principle.
xiii. Consumption and savings functions, marginal and average propensities to consume(MPS),
determinants and multiplier analysis
xiv. National income equilibrium: The Injection-Withdrawal approach and the aggregate output –
aggregate demand approach
xv. Multiplier Concept
2. MONEY, BANKING AND OTHER FINANCIAL INSTITUTIONS
i. Definition, types, feature and its functions
ii. Demand and supply of money
iii. Motives, determinants for demand and supply of money
iv. Central Bank, Money Deposit Banks, Microfinance Banks their roles and functions
v. Other financial institutions – Insurance, Credit Bureau, Bureau-de-change etc.
vi. The Capital market – Nigerian Stock Exchange (NSE) and Security and Exchange
Commission(SEC)
vii. Roles of money and capital market in economic development.
3. PUBLIC FINANCE
i. Concept of public finance
ii. Government revenue and Pattern of government expenditure.
iii. Theory of taxation – Categories and classification of taxation, objectives and functions
iv. National Budgets – types and its roles, sources of financing deficit budget
v. Economics of the public debts
vi. Fiscal and monetary policies: Meaning, objectives, instruments and limitations.
4. INFLATION AND UNEMPLOYMENT
i. Inflation-Definition, Types, Causes, Effects and control
ii. Unemployment-Definition, Types, Causes, Consequences and Remedies
5. GROWTH AND DEVELOPMENT
i. Distinction between growth and development
ii. Theories of economic growth and development
iii. Characteristics of developed and developing nations
iv. Problems of economic development in the third world countries
v. Roles of government in economic growth and developmental processes in Nigeria
vi. Development planning: Meaning, Objectives, Argument for and problem of development planning.
6. INTERNATIONAL TRADE AND FINANCE
i. International Trade-Definition and reasons for it, internal and international distinction
ii. Advantages/disadvantages of international trade
iii. Theory of comparative cost advantage
iv. Terms of trade, balance of trade and payments
v. Free trade and trade restrictions- Argument for and against
CITN 2020 SYLLABUS Page 31
vi. Balance of payment equilibrium and disequilibrium, causes and corrections
vii. Foreign exchange market and its functions
viii. Currency devaluation, depreciation and appreciation and their implications.
7. REGIONAL AND INTERNATIONAL ECONOMIC INTEGRATION
i. Roles/functions and contributions of:
• Economic Community of West African States(ECOWAS)
• African Union(AU)
• East African Community(EAC)
• South African Development Community(SADC)
• African Development Bank(ADB)
• World Trade Organization(WTO)
• Organization of Petroleum Exporting Countries(OPEC)
RECOMMENDED TEXTBOOKS
Adebayo, A. (1998) Economics: A simplified Approach, Volumes 1 &2, Lagos, African
International Publishing limited 1998, 1999
Dweivedi, D.N. (1997) Microeconomic Theory, Vikas Publishing House, New Delhi
Kontsoyiannis, A. Modern Microeconomics and Macroeconomic Theory
Nwankwo, G.O. Basic Economics for West African Students Paul Samuelson
Economics
Jhingan, M. (2015) Advanced Economic Theory
Lipsey, G.L. & C. Harbury First Principles of Economics (2nd Edition)
Gregory, M. (2008) Principles of Microeconomics (South-Western College publication)
Lipsey, G.L. Introduction to Macroeconomics (University of Toronto Press)
Akintoye I. R (2006) Principles of Public Finance, Glorious Hope Publications,
Lagos, Nigeria
Salawu, R. O. Essential of Public Finance, (Obafemi Awolowo University Press Ltd)
Ishola, K. A. Microeconomics (Cresthill Publishers Ltd)
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.
Vol. I &II
CITN Study Pack on Economics
ICAN Study Pack on Economics
CITN 2020 SYLLABUS Page 32
PROFESSIONAL TAXATION I
COURSE TITLE: FINANCIAL REPORTING
Aim
The financial accounting from the foundation level is taken up a level into financial reporting in the
context of more complex events and transactions with a greater emphasis on compliance with regulations
including International Accounting Standards and generally accepted accounting principles.
Candidates will be expected to demonstrate an understanding of and competence in financial statement
preparation, analysis, interpretation and reporting.
Main competencies
On successful completion of this paper, candidates are expected to be able to:
i. Explain the importance of a regulatory framework for accounting and reporting;
ii. Identify and state the circumstances in which private sector entities are required to prepare and present
statutory financial statements;
iii. Identify and state the laws, regulations accounting standards and other requirements that govern the
production of financial statements by public and private sector entities;
iv. Account for specific transactions in accordance with relevant international accounting standards;
v. Draft and present financial statements, or extract from them, of an entity and simple groups in
accordance with its chosen policies and in accordance with IFRS and local laws;
vi. Assess the circumstances in which the use of IFRS for companies may not be required;
vii. Analyse and interpret financial statements of an entity and simply groups; and
viii. Understand recent developments and ethical issues in the area of financial reporting.
Detailed Syllabus
A. Conceptual and regulatory framework for financial reporting
Conceptual Framework
i. Explain the meaning and purpose of conceptual framework.
ii. Explain the objectives, qualitative characteristics and limitations of financial statements.
iii. Discuss the underlying assumptions in preparing financial statements.
iv. Identify users of financial statements and their information needs.
v. Identify and discuss the components of financial statements.
vi. Explain the concept of capital maintenance.
vii. Differentiate between principle-based and rule-based financial reporting frameworks.
viii. Discuss accrual, cash and breakup bases of accounting.
CITN 2020 SYLLABUS Page 33
Regulatory framework
i. Identify and discuss laws, regulations, accounting standards and other requirements that govern
the preparation of financial statements.
ii. Identify and discuss relevant provisions of Companies and Allied Matters Act Cap C20 LFN
2004, and special pronouncements by regulatory authorities (CBN, NDIC, FRCN, NAICOM,
NSE, SEC, PENCOM, etc.)
iii. Explain the standard setting process of International accounting standards board (IASB) and
relationship with national standard setters.
iv. Discuss the process of adoption of IFRS and applicable local standards.
v. Explain the peculiar nature and relevant frameworks of specialized, not-for-profit and public
sector entities (including IFRS, national standards and IPSAS).
B. Accounting standards and policies relating to specific transactions in the financial statements
1 Tangible non-current assets (IAS 16)
Calculate (where necessary), discuss and account for tangible non-current assets in
accordance with the provisions of relevant accounting standards (IAS 16, IAS 20, IAS 23,
IAS 40, and IFRS 5).
2 Intangible non-current assets (IAS 38)
Calculate (where necessary), discuss and account for intangible non-current assets in
accordance with the provisions of relevant accounting standard (IAS 38).
3 Impairment of tangible and non-intangible assets (IAS 36)
Calculate (where necessary), discuss and account for impairment of tangible and
intangible non-current assets in accordance with the provisions of relevant accounting
standard (IAS 36), excluding financial assets and liabilities.
4 Fair value measurement, financial assets and liabilities
(a) Differentiate between debt and equity financial instruments.
(b) Calculate (where necessary), discuss and account for fair value measurement of
financial assets and liabilities in accordance with the provisions of relevant
accounting standards (IAS 32, IFRS 7 and IFRS 9, IFRS 13) with respect to
measurement, recognition, de-recognition and disclosures, excluding hedging but
including simple impairment cases.
5 Inventories and revenue from contracts (IAS 2, IAS 41, IFRS 15)
Calculate (where necessary), discuss and account for inventories and revenue from
contracts in accordance with the provisions of relevant accounting standards (IAS 2, IAS
41and IFRS 15).
CITN 2020 SYLLABUS Page 34
6 Provisions, contingent liabilities and contingent assets and events after the reporting
period (IAS 37, IAS 10)
Calculate (where necessary), discuss and account for provisions, contingent liabilities and
assets as well as events after the reporting period in accordance with the provisions of
relevant accounting standards (IAS 10, IAS 37).
7 Income Taxes (IAS 12)
Calculate (where necessary), discuss and account for income tax including current and
deferred tax in accordance with the provisions of relevant accounting standard (IAS 12).
C. Preparing and presenting separate financial statements
Preparation of financial statements
i. Calculate (where necessary), discuss and account for accounting policies and changes in
accounting policies in accordance with the provisions of IAS 8 – Accounting policies,
changes in accounting estimates and errors.
ii. Prepare and present entities’ separate financial statements including statement of financial
position, statement of profit or loss and other comprehensive income, statement of changes
in equity and relevant notes in accordance with IAS 1 – Presentation of financial
statements.
iii. Prepare and present statement of cash flows for single entity in accordance with IAS 7
using direct & indirect methods.
D. Preparing and presenting financial statements of simple group (parent, one
subsidiary and an associate)
1. Understanding a simple group
(a) Explain the concept of group especially a simple group and the objectives of
preparing group financial statements.
(b) Discuss the provisions of the relevant accounting standards for the preparation and
presentation of financial statements of simple group – (IAS 27, IAS 28, IFRS 3,
and IFRS 10), including the use of fair value for non-controlling interest.
(c) Calculate non-controlling interest using alternative methods and effect necessary
adjustments required to prepare the financial statements of simple group.
Preparation and presentation
i. Prepare and present statement of financial position of a simple group (one
subsidiary and an associate in accordance with the provisions of relevant standards
(IAS 1, IAS 27, IAS 28, IFRS 3 and IFRS 10).
ii. Prepare and present income statement including other comprehensive income of a
simple group (one subsidiary and an associate), in accordance with the provisions
of relevant standards (IAS 1, IAS 27, IAS 28, IFRS 3 and IFRS 10).
CITN 2020 SYLLABUS Page 35
iii. Prepare and present statement of cash flows of a simple group (one subsidiary and
an associate), in accordance with the provisions of IAS 7.
E. Financial statement analysis and interpretation
1 Understanding various types of analyses that financial statements may be subjected
to and ratios used in the analysis
i. Identify and discuss the types of analyses and interpretation of financial
statements.
ii. Discuss the various aspects of financial position and performance that may be
assessed (profitability, liquidity/solvency, gearing, investors’ returns) through the
analyses and interpretation of financial statements.
iii. Define ratio, identify and calculate various types of ratios used in the assessment
of financial position and performance of a business entity.
iv. Analyse and interpret computed ratios and assess the current period financial
position and performance of a business entity in comparison to (1) its prior period,
(2) another given entity for the same period and (3) industry average for the same
period.
v. Analyse and interpret computed ratios and assess the current period financial
position and performance of a simple group (one subsidiary and associate) in
comparison to (1) its prior period, (2) another given simple group entity for the
same period and (3) industry average for the same period.
vi. Discuss the use of cash flow statement in assessing liquidity and compare its
usefulness with that of a statement of profit or loss and other comprehensive
income when assessing liquidity and going concern of a business entity.
vii. Explain the use of earnings per share (EPS) in assessing the performance of
corporate entities in the capital market, especially capital market reaction to
earnings announcement.
Where necessary, write report as may be required when analysing and interpreting the financial
position and performance of a business entity and simple group, drawing conclusions, making
recommendations and giving advice from the perspectives of different stakeholders.
Limitations of analyses and interpretation of financial statements
i. Discuss the limitation of historic financial information in the analyses and interpretation
of financial statements.
ii. Explain how financial statements may be manipulated and discuss the impact of window
dressing and creative accounting on calculated ratios and how they can distort analyses
and interpretation of financial statements.
iii. Explain how analyses and interpretation of financial statements of specialized and not-for-
profit organizations differ from that of profit-oriented organizations.
iv. Explain why earnings per share (EPS) trend may be a better indicator of performance
when compared to a company’s profit trend and discuss the limitations of using EPS as a
performance measure.
CITN 2020 SYLLABUS Page 36
v. Explain why and how the use of consolidated financial statements might limit analyses
and interpretation techniques.
vi. Discuss the use of other information, including non-financial information relevant to the
assessment of an entity’s performance.
Ethics and current developments in financial reporting
i. Discuss developments around the inclusion of non-financial information in financial
reporting.
ii. Discuss new accounting standards in issue as may be specified from time to time.
iii. Discuss and apply ethical issues in financial reporting.
Applicable Accounting Standards:
Preface to IFRS
Conceptual Framework for Financial Reporting
IAS 1 Presentation of Financial Statements
IAS 2 Inventories
IAS 7 Statement of Cash Flows
IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors
IAS 10 Events after the Reporting Period
IAS 12 Income Taxes
IAS 16 Property, Plant and Equipment
IAS 20 Accounting for Government Grants and Disclosure of Government Assistance
IAS 23 Borrowing Costs
IAS 27 Separate Financial Statements
IAS 28 Investments in Associates
IAS 32 Financial Instruments: Presentation
IAS 36 Impairment of Assets
IAS 37 Provisions, Contingent Liabilities and Contingent Assets
IAS 38 Intangible Assets
IAS 40 Investment Property
IAS 41 Agriculture
IFRS 3 Business Combinations
IFRS 5 Non-current Assets Held for Sale and Discontinued Operations
IFRS 7 Financial Instruments: Disclosures
IFRS 9 Financial instruments
IFRS 10 Consolidated Financial Statements
IFRS 13 Fair Value measurement
IFRS 15 Revenue from contracts with customers
All new standards may be examined after six months from the date of issue
All applicable laws may be examined after six months from date of amendment or enactment
CITN 2020 SYLLABUS Page 37
RECOMMENDED TEXTBOOKS:
Adamu, S. O. and JohnsonT. L. Statistics for Beginners, Evans, Nigeria
Akintoye, I.R. (2016), Investment Decisions in the 21st century, Unique
Educational Publishers, Lagos
Alan Melville International Financial Reporting A Practical Guide, 5th
Edition, Pearson Education Ltd
Ann Jorissen, Anne Britton, David Alexander International Financial Reporting and Analysis, Cengage
Learning EMEA; 6th Revised edition edition (April 12,
2014)
CITN Tax Guide and Statutes
Jennifer Maynard Financial Accounting, Reporting and Analysis, Oxford
University Press
Prince Casmir Idekwulim Teach yourself Group Accounting
Prince Casmir Idekwulim Teach yourself IFRS
Shuaib Adeadebayo Abdulkabir IFRS Relief, for Finance, Corporate and Strategic
Business, Topnotch Learning Centre Ltd
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.
Vol. I &II
David Alexader, Anne Britton -International Financial Reporting and Analysis
Lanre Owoeye -Corporate Financial Reporting made simple on IFRS
Applications
Walton and Aerts -Global Financial Reporting and Analysis
CITN 2020 SYLLABUS Page 38
COURSE TITLE: INCOME TAXATION
Course Description:
The course provides a structured approach to students gaining knowledge into the direct tax laws in force and
insight into procedural aspects of assessment of tax liability for various taxpayers. It also provides an in-depth
study of the various provisions of the direct taxation laws and their impact on business decision-making.
Prerequisites: Principles of Taxation, Financial Accounting and Financial Reporting.
Aims and Objectives of the Course:
At the end of this paper, candidates will be able to:
i. Understand the detailed principles underlying the Companies Income Tax Act, Tertiary Education
Tax Act, National Information Technology Development Agency Act, Personal Income Tax Act and
Capital Gains Tax Act
ii. Compute the taxable income of a taxpayer
iii. Understand the assessment procedures and representation before appropriate authorities under the
law
iv. Understand the available objection and dispute resolution processes
COURSE CONTENTS
1. ACCOUNTING STANDARDS
i. Impact of accounting standards on taxable profit
ii. Deferred tax and difference between income tax and levy under IFRS (IAS 12 and IFRIC 21)
2. ADMINISTRATION OF COMPANIES INCOME TAX
i. Constitutionality of income tax and administrative powers of the Federal Inland Revenue
Service
ii. Requirement that all companies shall keep books of accounts and the penalty for failure to
provide any record or book - section 63 of CITA (as amended)
iii. Registration
iv. Types of assessment (Government assessment, turnover basis of assessment/best of
judgment/administrative assessments, self-assessment)
v. Objection and appeals process (Time limit for appeals, contents of notices of assessment,
contents of notices of objection, amendment of assessments and notice of refusal to amend, Tax
Appeal Tribunal, Courts etc.)
vi Statute of limitation and powers of the tax authorities to audit open years, noting the decision of
CITN 2020 SYLLABUS Page 39
TAT, Benin Zone, restricting the powers of tax authorities to assess taxpayers to back-duty except
where fraud, willful default or neglect on the part of the taxpayer has been established by a
Tribunal or a court of competent jurisdiction.
vii. Components of the tax returns (capital allowances, financial statements, assessment forms, etc.)
viii. Tax return to be filed by a company other than a Nigerian company to the tax office - section
55(1A) of CITA (as amended)
ix. Powers of the Service to specify the form of accounts to be included in a tax return by small and
medium-sized companies – section55 ((7) of CITA (as amended)
x. Filing due date and payment due date (including resolving the conflicts between the self-
assessment regulations and the Companies Income Tax Act), taking into consideration the
provisions of section 77(5), (5A) and (5B) of CITA (as amended)
xi. Tax clearance certificate (content, timing for issuance of tax clearance certificate, conclusions
reached from the Warm Spring and Ors vs FIRS on issuance of TCC)
3. SCOPE OF COMPANIES INCOME TAX, TERTIARY EDUCATION TAX, NIGERIA
INFORMATION TECHNOLOGY DEVELOPMENT LEVY
i. Persons Chargeable for the various taxes
• Definition of Nigerian and Foreign companies,
• Definition of companies liable to NITDA levy, examples and ambiguities
ii. Treatment of residents and non-resident companies
iii. Capital vs revenue – receipts, expenditures
iv. Concept of business profits and passive/investment income
v. Definition of Non-resident companies (NRCs) under the CITA.
vi. Legal Basis of Income Taxation for NRCs – Reference to Section 13 (2) of the CITA
vii. Define and explain the concepts of fixed base; dependent agent; turnkey projects and arms-length
transaction and how they apply to NRCs.
viii. Determination of CIT payable by NRCs (candidates are to note that the basis for arriving at the
taxable profits is similar for Nigerian companies – however, reference should also be made to the
turnover method – Deemed profit model)
ix. Basis for non-payment of Tertiary Education Tax for NRCs
x. Other special issues which include:
• Capital importation and repatriation issues which typically arise from the absence of a
certificate of capital importation.
• Format of audited accounts used in tax filing
• Obligation to withhold tax on payments to vendors
CITN 2020 SYLLABUS Page 40
4. COMPUTATION OF COMPANIES INCOME TAX, TERTIARY EDUCATION TAX AND
POLICE FUND LEVY
i. Definitions of small, medium-sized and large companies
ii. Allowable and non-allowable expenses
iii. Expenses incurred in deriving exempt income
iv. Restriction on cost of donations to any fund set up by government relating to any pandemic or
natural disaster based on the Finance Act, 2019
v. Tax or penalty borne by a company on behalf of another person
vi. Interest on loan – gas utilization (downstream operations)
vii. Incentives available to a company engaged in a trade or business of gas utilization in downstream
operations
viii. Restrictions on the deductibility of interest in respect of debt issued by a foreign connected person
to a Nigerian company
ix. Tax exemption on interest on foreign loans
x. Exemption from tax the profits of a Nigerian company in respect of goods exported in line with
the provision of section 23(1q) of CITA (as amended)
xi. Incomes chargeable to tax and incomes exempted from tax
xii. Definition of gross turnover
xiii. Adjustment of income for tax purposes
xiv. Difference between assessable profit and total profit
xv. Determination of basis period based on the provisions of the Finance Act, 2019
xvi. Currency for tax settlement and implications for functional currency,
• exchange losses (realized vs unrealized)
• Conversion of foreign currency income to Naira for ₦10 retention for capital allowances,
small companies tax rate and percentage applied to turnover for minimum tax purposes
xvii. Commencement rule, change of accounting date and cessation rule, taking into consideration the
provisions of the Finance Act, 2019
xviii. Qualifying capital expenditure
xix. Capital allowances, including the treatment of capital allowances for small companies
xx. Treatment of research and development costs (capital, revenue and provisions) and rural
investment allowance
xxi. Loss relief
xxii. Computation of CIT
xxiii. Determination of dividends paid out of retained earnings in line with the provisions of the Finance
Act, 2019
xxiv. Exemption of small companies from the payment of income tax
xxv. Scope of minimum tax provision and minimum tax computation - section 33 of CITA (as
amended)]
xxvi. Treatment of dividend income and distributions (including definition of dividend, franked
investment income and treatment of profits of holding companies, treatment of non-distribution
of dividend for company with 5 shareholders or less)
CITN 2020 SYLLABUS Page 41
xxvii. Computation of Tertiary Education Tax (TET)
xxviii. Computation of Police Fund Levy at 0.005% of the net profits of companies operating in Nigeria
based on the provisions of the Nigeria Police Trust Fund (Establishment) Act, 2019
5. CAPITAL GAINS TAX
i. Nature and objectives of Capital Gains Tax
ii. Administration of Capital Gains Tax
iii. Charge to tax and persons chargeable
iv. Chargeable assets and examples (including examples of property created by the person disposing
of it, or otherwise coming to be owned without being acquired)
v. Exemptions, including assets transferred or sold in business reorganisation and reorganisation,
and exclusions
vi. Allowable and disallowable expenditure
vii. Treatment of residents with assets inside Nigeria and assets outside Nigeria
viii. Treatment of non-residents with assets inside Nigeria and treatment of non-residents with assets
outside Nigeria
ix. Definition of location of assets (movable vs immovable) for CGT purposes
x. Exclusion of losses, part disposal of assets and roll-over relief
xi. Treatment of compensation for loss of office in line with the provision of the Finance Act, 2020,
retirement benefit schemes, policy of insurance and instances where no asset is acquired by the
person paying the capital sum
xii. Date of acquisition and valuation of assets (including artificial transactions and transactions
between connected persons)
xiii. Part disposal of assets and bargains comprising 2 or more transactions
xiv. Anti – Avoidance Provision - section 44(3) of CGTA (as amended)
xv. Responsibility of the person who pays compensation for loss of office to an individual to deduct
and remit the tax due within the time specified under the Pay-As-You-Earn regulations to the
relevant tax authority
xvi. Computation of Capital Gains Tax, filing of self- assessment return and remittance of tax on
chargeable assets disposed in line with the provision of section 2(4) of CGTA (as amended)
xvii. Delayed Remittances Relief
xviii. Offences and penalties
CITN 2020 SYLLABUS Page 42
6. ADMINISTRATION OF PERSONAL INCOME TAX
i. Constitutionality of income tax and administrative powers of the State Internal Revenue Service
and Joint Tax Board
ii. Registration for personal income tax and PAYE
iii. Types of assessment (Direct assessment, self-assessment system and PAYE)
iv. Objection and appeals process (Time limit for appeals, contents of notices of assessment, contents
of notices of objection, amendment of assessments and notice of refusal to amend, Tax Appeal
Tribunal, Courts etc.)
v. Statute of limitation and powers of the tax authority, noting the decision of TAT, Benin Zone,
restricting the powers of tax authorities to assess taxpayers to back-duty PAYE except where
fraud, willful default or neglect on the part of the taxpayer has been established by a Tribunal or
a court of competent jurisdiction
vi. Components of the tax returns
vii. Filing due date and payment due date
7. PERSONAL INCOME TAX ON INDIVIDUALS
i. The charge to tax and persons chargeable
ii. Persons exempted from the payment of personal income tax
iii. Principle of residence and determinants of relevant tax authority
iv. Taxation of non-resident individuals
v. Computation of chargeable incomes
vi. Definition of gross income for purposes of claiming personal relief by the owner of an enterprise
based on Finance Act, 2020
vii. Computation of minimum tax
viii. Computation of PIT, rates, etc.
ix. Earned income vs unearned income
x. Reliefs, Charges and statutory deductions
xi. Income Tax Aspects of Transparent vehicles - Trusteeship, Partnerships etc.
• Trust
• Settlements
• Estates
• Partnerships
• Existing partnership
• Commencement of partnership
• Dissolution of partnership
• Admission of new partner(s)
CITN 2020 SYLLABUS Page 43
8. OPERATION OF PAY AS YOU EARN (PAYE)
i. Status – employed vs self-employed/contractor and implication for PAYE vs Withholding Tax
ii. Responsibility for PAYE (employer and manager) – agency workers and managed services
scenarios
iii. Earnings and benefits treated as income and exclusion for employment related expenses
iv. Exemption of an employee from the payment of personal income tax where such a person earns
gross income of National Minimum Wage or less
v. Definition of gross income for personal relief purposes based on Finance Act, 2020
vi. Deductions allowed from employment Income
vii. Taxation of expatriate employees
viii. Valuation and Taxability of Perquisites, Benefit-in-kind, non-payroll allowances, benefits and
other contentious issues under PAYE
• Gratuity
• Payment in lieu of notice
• Reasonable removal expenses
• Per diem and estacodes
• Employer provided loans and advances
• Employer provided accommodation
• Reimbursable expenses
9. WITHHOLDING TAX ON COMPANIES AND INDIVIDUALS
i. Treatment of non-residents for business profits and passive income
ii. Determination of employee for PAYE vs contractor for WHT
iii. Items subject to WHT and exemptions for sales in the ordinary course of business and capital
sums, considering the decision of the Tax Appeal Tribunal, Lagos zone on November 30, 2020,
in a case between Tetra Pak West Africa Limited and Federal Inland Revenue Service
iv. Other exemptions from withholding tax
v. Treatment of passive income for withholding tax purposes
vi. The obligation of third parties to deduct withholding tax from payments to any tax – exempt
company - section 23(1) of CITA (as amended) and remit same to FIRS
vii. Request for refund of withholding tax suffered where a company has fulfilled the condition for
the exemption of its profit from tax
viii. Provision of Withholding Tax rate of 2.5% on contracts for the construction of roads, bridges,
buildings and power plants
CITN 2020 SYLLABUS Page 44
RECOMMENDED TEXTS
Adesola, S. M. Income Tax Law and Administration in Nigeria (O. A. U. Press)
Abdulrazaq, M. T. Nigerian Tax Offences and Penalties (Batay Law Publications)
Oni, I. O. Nigerian Companies Income Tax: Law & Practice
Teju Somorin Teju Tax Reference Book. Malthouse Press Limited, 2012 Edition.
Offiong U. B. Companies Taxation in Nigeria. 2016 Edition
Joseph A. A. Nigerian Income Tax & Its International Dimension
CITN Tax Guide and Statutes
CITN Study Pack on Taxation
ICAN Study Pack on Taxation
Abdullahi Danjuma Zubairu - Understanding Nigerian Taxation
Offiong Bassey Income Taxation
Gboyega Adejuwon Analysis of Taxation Principles Vol. 1
Offiong Bassey Nigeria Taxation
Olugbenga Obatola Rudiments of Nigerian Taxation
Soyode & Sunday Kajola Taxation Principles and Practice in Nigeria
Arowomole & Oluwakayode A Classic Introduction to Nigerian Taxation
Idowu Abiola & Fasina H. T.
CITN 2020 SYLLABUS Page 45
COURSE TITLE: INDIRECT TAXATION
Course Description:
The course provides student with in depth knowledge of the indirect tax laws in force and insights into procedural
aspects of assessment of tax liability for various taxpayers. It also provides a detailed study of the various
provisions of indirect taxation laws and their impact on business decision-making.
Prerequisites: Principles of Taxation and Financial Accounting
Aims and Objectives of the Course:
At the end of this paper, candidates will be able to:
i. Understand the principles underlying the Indirect Taxation Statutes with reference to:
• Customs and Excise Management Act;
• The Customs, Excise Tariff, etc. (Consolidation) Act
• Stamp Duties Act;
• Hotel Occupancy, Restaurants and Event Centre Consumption Tax Laws;
• Value Added Tax;
• Cabotage and local content levies,etc.; and
• Taxes application to transfer and use of property.
ii.Compute the assessable value of transactions related to goods and services for levy and
determination of duty liability and VAT liability.
iii. Identify and analyze the procedural aspects under different applicable statutes related to indirect
taxation.
COURSE CONTENTS
1. LEGAL BASIS AND NATURE OF INDIRECT TAX
i. Constitutional validity of Value Added Tax (VAT), consumption tax and various levies
(including taxes introduced by enactment of new laws)
ii. Features of indirect tax
iii. Powers to administer various indirect taxes and sharing formula between tiers of -Government
for Value Added Tax
iv. Powers of state governments to collect consumption tax
2. HISTORY OF VAT AND GENERAL PRINCIPLES
i. General definition of VAT
ii. Difference between variant of VAT practiced in Nigeria and the variant practiced in most parts
of the world.
CITN 2020 SYLLABUS Page 46
iii. International principles for cross border - Destination versus origin principles
3. IMPOSITION OF VAT
i. Scope of coverage
• Definition of taxable person
• Definition of supply including
- Application of the tax on leases with a focus on what constitute taxable goods
given the use of the phrase “letting of taxable goods….”
- Definition of taxable goods and services (lack of definition vs definition in sale
of goods Act and the Black Law’s dictionary)
- Out of scope transactions - Federal High Court in the Judgment between the
Federal Inland Revenue Service (FIRS) and CNOOC
• Responsibility of Government Ministries and Agencies
• Non-Resident Companies
ii. Schedule of exempt items –
• Exemptions in the law vs exemptions by the FIRS information Circulars
• Clarification on whether VAT would apply on any transaction which is not specifically
exempted in the VAT Act
iii. Schedule of zero-rated items with examples
iv. VAT compliance threshold
v. Definition and application of VAT on imported goods and services including value of
imported goods.
vi. Definition and application of VAT on exported goods and services – compared and
contrasted with destination and origin principles
vii. When goods and services shall be deemed to be supplied in Nigeria in accordance with
section 33(2) of the Finance Act, 2019
viii. Basic tax point
ix. Actual tax point
x. Computation of VAT liability, including the treatment of opening and closing
inventories
xi. Self-account provision for which VAT was not charged
xii. Treatment of VAT on sale and transfer of assets amongst related parties in business
reorganization and restructuring
xiii. Treatments of VAT on property, plant and equipment purchased,and operating expenses
4. ADMINISTRATION OF VAT
i. Nature, objectives and administration of VAT
CITN 2020 SYLLABUS Page 47
ii. Timeline for registration – commencement of business or commencement of the Act and
how it applies to new businesses.
iii. Process of registrationand deregistration for VAT
iv. Obligation to register for VAT by Non-resident companies
v. VAT enforcement and practice
vi. VAT audit and investigation
vii. VAT recovery
viii. Value Added Tax Technical Committee
ix. VAT Tribunal
x. Merits and demerits of VAT
5. RETURNS, PAYMENT AND OFFENCES
i. Obligation to issue a tax invoice, description of a tax invoice and information that must be given
on a VAT invoice
ii. Definition of output tax
iii. Definition of input tax and allowable input tax
iv. Obligation to deduct the tax at source (application to Government Ministries, Agencies, Non-
resident companies (NRCs) and Oil and gas Industry)
v. Impact of obligation to deduct on Oil and gas industry and allowable input VAT claim in the
industry
vi. Obligation (specifically who is obliged to) and timeline for submitting returns
vii. Obligation to remit and timeline for remitting tax collected
viii. Cash vs Accrual method of reporting and payment of VAT
ix. Penalties
• Provision of false documents
• Evasion of tax
• Failure to notify change of address
• Failure to issue a tax invoice/issuance of a tax invoice by unauthorized persons
• Failure to register
• Failure to submit returns
• Failure to keep records
6. CUSTOMS AND EXCISE DUTIES
i. Nature, objectives and administration of customs and excise duties
ii. Provisions relating to the furnishing of information by manufacturers and keeping of goods
iii. Delivery terms (incoterms) – impact on liability for duty and VAT
iv. Tariff classification and rates of duty
• Rules of classification
• Tariff quotas, tariff suspensions and reliefs
- Duty drawback and duty draw back facilities
CITN 2020 SYLLABUS Page 48
- Temporary importation permits
- Bonded warehouse
- Export Processing Zones
- ECOWAS Trade Liberalization Scheme
iii. Customs valuations
iv. Procedural aspects for importation and exportation
• Prohibitions and restrictions on imports and exports
• Import license
• Export license
• Regulators – Nigerian Export Promotion Council, Nigerian Customs Service, Standards
Organisation of Nigeria, Nigeria Agency for Food and Drug Administration and
Control, etc
v. Export Expansion Grant
vi. Excise duties
• Goods imported into Nigeria that are to be charged with duties of excise in line with the
relevant provision of the Finance Act, 2019
• Dutiable liquor and tobacco products and statutory definitions
• Valuation of goods for excise duty purposes
• Excise factory
• Removals and warehousing
vii. Offences and penalties
7. STAMP DUTIES
i. Nature and objectives
ii. Definitions
iii. Administration
iv. Types and forms of stamp duties
v. Chargeable interests, transactions and consideration
vi. Ad valorem and fixed charge and schedule of rates and charges, including those on loans and
credit facilities
vii. Exemptions and reliefs (transfer of shares, transfer of property within a group, acquisition of
vessels etc.)
viii. Instruments specifically exempted from stamp duties by the Finance Act, 2019 and Central
Bank Circular number CBN/GEN/DMB/02/006 dated January 15, 2016
ix. Electronic documents received in Nigeria
x. Duty upon receipts
CITN 2020 SYLLABUS Page 49
xi. Duty on contracts
xii. Collection of stamp duty on rent payable to a landlord
xiii. Consequences for non-compliance with the provisions of the Stamp Duties Act Cap S8 LFN
2004 (as amended)
xiv. Recent developments and cases on stamp duties e.g. Stanbic IBTC vs FIRS on N50 stamp duty
8. OTHER INDIRECT TAXES AND TRENDS
i. Other indirect taxes
• Niger Delta Development Commission Fund
• Hotel Occupancy and Restaurant Consumption Tax
• Levies imposed by the Nigerian Maritime Administration and Safety Agency
• Local content surcharge imposed on transactions in the oil and gas industry
• Governor’s consent and taxes applicable to transfer of property
• Tenement rates and taxes on utilization of property
ii. Recent trends
• Electronic fiscal devices
• Base Erosion and Profit Shifting proposals on the digital economy (taxing remote digital
supplies)
9. ETHICAL ISSUES ON INDIRECT TAXATION AND TAX PRACTICE STANDARDS
i CITN Code of Conduct in relation to Indirect Taxation
ii Moral and common ethical issues in tax practice relating to indirect taxation
iii Subsisting CITN Statements of Taxation Standards (STS) in respect of the practice of
Taxation in Nigeria
10. CASE LAW (Case Study)
i Case Study on VAT using decided cases (Federal High Court, TAT, etc decisions
ii Case Study on Stamp Duties using decided cases by the Court of Appeal
iii Case Study on Customs and Excise Duties using decided cases by the Supreme Court
RECOMMENDED TEXTS
CITN CITN Nigerian Tax Guide and Statutes
Abdulrazaq, M.T. Introduction to Nigerian Customs and Excise Duties (CITN)
Various laws: Nigerian Oil and Gas Content Development Act,
Stamp Duties Act,
Value Added Tax Act, etc
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.
Vol. I &II
CITN Study Pack on Taxation
ICAN Study Pack on Taxation
CITN 2020 SYLLABUS Page 50
COURSE TITLE: GOVERNANCE, RISK AND
ETHICS
Course Description:
This course seeks to enhance candidates’ level of knowledge on contemporary business issues including
business organization, management functions and processes, strategic management, effective risk management
framework, sound corporate governance and importance of ethics in a business environment.
Prerequisite: Corporate Law, Economics, Principles of Taxation, Income Taxation, and Taxation of specialised
businesses.
Aims and Objectives of the Course:
At the end of this paper, candidates will be able to:
i. Discuss business organisations, management functions and processes.
ii. Discuss strategic management process including its benefits, distinguish between policy and strategy,
and explain the elements of SWOT analysis.
iii. Explain the concept of risk, risk management and Enterprise Risk Management
iv. Discuss risk management framework and state some international risk management standards
v. Define governance and explain the principles of good governance for both private and public sector
vi. Understand the importance of ethics, including tax transparency and morality, to the larger business
society.
vii. Explain the ethical code of conduct as provided in CITN Professional Rules and Practice Guidelines
(PRPG).
viii. Identify CITN Statements of Taxation Standards (STS) applicable to specific business scenarios.
ix. Explain the concept of Emotional Intelligence and the effect on Business success.
COURSE CONTENTS
1. BUSINESS ORGANISATION
i. Types of business organisations
a. Nature and purpose of organizations
b. formal and informal organisation
ii. Environment of Business
a. Internal and external environment
b. Environmental scanning
c. Stakeholders
iii. Business organisational design and structures
a. Centralised vs decentralised
b. Matrix and mixed
c. Networks and virtual arrangements
iv. Organisational behaviour and culture
v. Roles of teams and management committees in business
vi. Impact of technology on organisations
a. Business model adopted
b. Organisational structure
CITN 2020 SYLLABUS Page 51
c. Downsising
d. Delayering
e. outsourcing
2. MANAGEMENT FUNCTIONS AND PROCESSES
i. Management functions
a. Planning
b. Organising
c. Controlling
d. Directing
e. Coordinating
f. supervising
ii. Leadership and motivation
iii. Communication in business
a. Forms of communication
b. Communication process
c. Meetings and report writing
d. Electronic mode of communication
e. Barriers to communication
iv. Conflict and conflict resolution in organisations
a. Causes of conflicts in organisations
b. Conflict management techniques including referrals
v. Functional management
a. Human resource
• Recruitment and selection
• Learning and development
• Performance management
• Employee relations
• Career planning
b. Production
• Production planning and control
• Product selection and design
• Production process selection
• Quality and cost control
• Inventory management
• Equipment maintenance and replacement
c. Marketing
• Marketing concepts and principles
• Marketing vs sales
d. Finance
• Budget and budgetary control
• Treasury and cash management
• Costing and cost control
• Management and final accounts
CITN 2020 SYLLABUS Page 52
• Security against fraud and money laundering
e. Information technology
• Procurement
• Organisation
• Security
• governance
3. STRATEGIC MANAGEMENT
i. Concept of Strategic management
ii. Strategy definition and features
iii. Components of strategy statements
• Strategic intent
• Mission statement
• Vision
• Goals and Objectives
iv. Strategic management process
• Environmental scanning
• Strategy formulation
• Strategy implementation
• Strategy evaluation
v. Comparison of strategy formulation and strategy implementation
vi. Definition and characteristics of strategic decisions
vii. Benefits of strategic management
• Financial benefit
• Non-financial benefit
viii. Definition and features of business policy
ix. Difference between business policy and strategy
x. Definition, advantages and limitations of SWOT Analysis
xi. SOAR analysis
xii. Assessment of e-Business
• Principles of e-Business
• E-Business Application (Purchasing & Supply, Relationship Management, Taxation)
4. RISK MANAGEMENT:
i. Meaning and types of risk
ii. Components of business risk including risks arising externally or internally and relating to
achievement of:
CITN 2020 SYLLABUS Page 53
• Strategic objectives
• Operational efficiency and effectiveness
• Reliable reporting
• Legal, regulatory and ethical compliance
iii. Meaning and principles of risk management
iv. Risk management framework
• Risk assessment
- Inherent risk
- Residual risk
• Risk management process
- Identification; Analysis; Evaluation & Ranking; Response Planning; Monitoring
& Review
• Risk monitoring
• Risk mitigation strategies
• Risk response strategies
v. Relationship between risk management, governance, internal control and compliance.
vi. Tax Audit Risk Assessment
vii. Meaning and concept of Tax risk Management framework.
5. GOVERNANCE:
i. Meaning and concept of governance and corporate governance
ii. Nature, significance and scope of enterprise governance and threats to effective governance, iii. Concept of good governance; Roles of internal and external auditors, board structure; and
audit committee in good governance. iv. Rules-based and principles-based approaches to corporate governance. v. Definition and principles of good governance
• Fair conduct of elections, representation and participation
• Responsiveness
• Efficiency and Effectiveness
• Openness and transparency
• Rule of law
• Ethical conduct
• Competence and capacity
• Innovation and openness to change
• Sustainability and long-term orientation
• Sound financial management
• Human rights, cultural diversity and social
• Accountability
vi. Nature, significance and scope of enterprise governance
vii. Threats to effective governance from tax perspective
viii. Role and responsibilities of an effective board
ix. Roles and responsibilities of board committees
x. The Issue of ‘non-compliance with laws and regulations’ (NOCLAR) in relation to the responsibilities of the board.
xi. Nature of the oversight functions of a board and institutional shareholders over management.
CITN 2020 SYLLABUS Page 54
xii. Importance of probity as a principle of governance assessing issues and their implications in a
given scenario.
xiii. Principles of good governance in the public sector
• Professional ethics
• Professionalism
• Leadership
• Accountability
• Transparency
• Participation
• Responsiveness
• Compassion and humanity
xiv. Governance issues in the accountability of management to the board, shareholders and other
stakeholders.
xv. Scope, background and concept of Corporate Social Responsibility (CSR) and Sustainability in
business.
xvi. Definition and explanation of Tax morality, Voluntary tax compliance and Tax transparency.
xvii. Definition and application of Tax Justice concept
xviii. Recent global development in enterprise and corporate governance.
xix. Relevant national and international codes of corporate governance.
6. ETHICS:
i. Definition of ethics, sub-divisions of ethics, (descriptive, normative and meta-ethics) and the relationship between ethics and law.
ii.
iii. Distinguishing features of ethics and morality
iv. Moral duties and moral dilemma
v. Fundamental principles of ethics
• Principle of respect for autonomy
• Principle of beneficence
• Principle of non-maleficence
• Principle of justice
vi. Professional ethics and business ethics
vii. Principles of Business ethics (i.e. ethical principles in the workplace)
• Honesty
• Integrity
• Promise-keeping and trustworthiness
• Loyalty
• Fairness
• Concern for others
• Respect for others
• Law abiding
• Commitment to excellence
• Leadership
• Reputation and morale
• Accountability
viii. Relationship between business ethics and business success
CITN 2020 SYLLABUS Page 55
ix. Business ethics and corporate social responsibility
x. Models of professional-client relationship; agency, contract, paternalism and fiduciary. 6
xi. Corruption, Fraud and fraudulent behaviour in organizations including money laundering,
bribery, embezzlement, theft, fraud, extortion, and blackmail xii. Whistle blowing
xiii. Principles of professional ethics
xiv. Ethical threats and their safeguards
xv. Ethical principles for CITN Tax Professionals in accordance with Statement of Taxation
Standards (STS) and the Professional Rules and Practice Guidelines (PRPG)
7. EMOTIONAL INTELLIGENCE:
i. Definition and meaning of Emotional Intelligence (EI)
ii. Competencies/Types of Emotional Intelligence
• Self-awareness.
• Self-regulation.
• Motivation.
• Empathy.
• Social skills.
iii. Comparison of Emotional Intelligence and Intelligent Quotient (IQ)
iv. Importance of Emotional Intelligence to business success
• Staff motivation
• Better working environment
• Escalation of business success
• Team spirit and bonding
• Elimination of communication barrier
RECOMMENDED TEXTS
Ricky W. Griffin (2017) Management, 12th Edition, Centage Learning
William Nickels, James McHugh, Susan McHugh (2018) Understanding Business, 12th Edition, McGraw-
Hill Education
David, K. (2017). Tax Strategy (The Nitty-Gritty Practice)
Oyedokun, G. E. (2017). Fundamentals of Leadership: ASCO Publishers; Lagos Nigeria
Oyedokun, G. E. (2019). Business policy, strategy & ethics. Lagos, Nigeria. Aaron & Hur
Publishing.
CITN Tax Guide and Statutes
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.
Vol. I &II
CITN 2020 SYLLABUS Page 56
CITN Study Pack on Governance and Ethics
ICAN Study Pack on Governance and Ethics
INTERNET SOURCES
1. Strategic Management by Management Study Guide <http://www.managementstudyguide.com/>
2. What are the 5 Risk management Steps in a Sound Risk management process?
<http://continuingprofessionaldevelopment.org/risk-management-steps-in-risk-management-
process/>
3. 12 Principles of good governance and European Label of Governance Excellence (ELoGE)
<https://www.coe.int/en/web/good-governance/12-principles-and-eloge/>
4. Josephson Institute of Ethics
<http://josephsononbusinessethics.com/2010/12/12-ethical-principles-for-business-executives/>
5. 12 Principles of good governance and European Label of Governance Excellence (ELoGE)
<https://www.coe.int/en/web/good-governance/12-principles-and-eloge/>
6. Josephson Institute of Ethics
<http://josephsononbusinessethics.com/2010/12/12-ethical-principles-for-business-executives/>
CITN 2020 SYLLABUS Page 57
PROFESSIONAL TAXATION II
COURSE TITLE: TAX AUDIT AND INVESTIGATION
Course Description:
The course is designed to cover the audit of all the variables in the income statement, the balance sheet and the
cash flow statement identifying the tax audit risk issues and risk assessment. It also covers the investigation of
fraud, error of omission or commission and intentional manipulation of the variables in order to lessen the
taxpayer’s tax liability.
Candidates must have prerequisite knowledge of principles of taxation and financial accounting at Foundation
level as well as practice of income and indirect taxation, and income tax for specialized businesses at Professional
level I.
Aims and Objectives of the Course:
The aim of this course is to enable candidates to have the knowledge and skill of identifying the risky areas in
tax audit and investigation (such as financial misstatements, tax evasion and tax avoidance schemes) and provide
mechanism to counter Tax Avoidance and Tax Evasion.
At the end of this course, candidates should be able to:
i. Explain the concept of tax audit and investigation, identifying the differentiating features of the two
concepts.
ii. Discuss tax audit and investigation principles
iii. Explain the process for planning tax audit and investigation
iv. Describe the process for controlling and recording tax audit and investigation
v. Explain interview techniques for tax investigation
vi. Explain the determination of audit evidence and understand audit techniques and procedures
vii. Describe risk based audit approach
viii. Explain the statutory powers of tax auditors and investigators
ix. Describe tax audit procedures and risk assessment
COURSE CONTENTS
1. INTRODUCTION TO AUDIT AND INVESTIGATION
i. Meaning and objective of auditing and investigation
ii. Merits and demerits of auditing and investigation
iii. Qualities of an auditor and investigator
iv. Fundamental principles of auditing
v. Concept of expectation gap in auditing
vi. Differentiation between Tax Audit and Statutory Audit
vii. Differentiation between the Internal Auditor, External Auditor and Tax Auditor
CITN 2020 SYLLABUS Page 58
2. TAX AUDIT/INVESTIGATION PRINCIPLES
i. Definition, nature and purpose of tax audit/investigation
• An overview of tax audit
• Classification and types of audit, etc.
ii. Rules and objectives of tax audit/investigation
• Legal framework for tax audit
• Tax audit fundamentals
iii. Difference between a tax audit and a tax investigation
• The issue of forensic audit, legal issues and the role of the tax auditor
iv. Reasons for tax audit and tax investigation
• Factors for selecting taxpayer for tax audit/ investigation
• Qualities of a good tax audit and tax investigation exercise
v. Appointment of tax auditors
vi. Duties, rights and obligations of tax auditors
vii. Taxpayers rights and obligation
viii. Professional responsibilities
• Competencies and ethics of audit staff
• Tax auditor’s independence
3. PLANNING OF TAX AUDIT AND INVESTIGATION
i. Sources of taxpayers’ financial and business information
ii. General consideration, nature of business, industry, business cycle and tax compliance history
iii. Audit/Investigation staffing and logistics
iv. Preparation of tax audit/investigation programmes
• Audit management and control
• Case selection and assignment
• Audit planning and preparation
• Basic tax audit tools and techniques
- Use of mark-ups
- Use of input/output ratios
- Use of tax performance ratios
- Other audit techniques
4. CONTROLLING AND RECORDING AN AUDIT/INVESTIGATION
i. Review of accounting system
• Review of Receipts & Vouchers, the primary books of accounts, cash flow, etc.
• The examination of the ledgers, control accounts and the trial balance
• Tax examination of the income statements particularly salient variables e.g. sales,
administrative expenses, closing stock, etc.
• Tax examination of the balance sheet, particularly the current assets, current liabilities
and the working capital, to check liquidity risk.
ii. Allocation and supervision of work
CITN 2020 SYLLABUS Page 59
iii. Documentation of work done
• Documentation
• Report writing
iv. Management of working papers
v. Evidence of proper review, conclusion and action steps
vi. Management of commencement and close-out meetings
vii. Preparation of audit/investigation report
viii. Decision making after tax audit/investigation
• Audit/Investigation closure
ix. Conflicts resolution and settlement of tax disputes
5. INTERVIEW TECHNIQUES
i. Preparation for interview
ii. Managing the interview process
• Managing eye contact
• Reading facial expressions and body language
iii. Documentation of minutes of meetings and interviews
iv. Human relation aspects of field interview
6. AUDIT EVIDENCE, TECHNIQUES AND PROCEDURES
i. Nature of audit evidence
ii. Relevance and reliability of audit evidence
iii. Audit techniques, inspection, observation, enquiry
• The elements of risk, fraud and error,
• The application of forensic audit and substantive audit techniques.
iv. Forensic accounting/audit techniques
v. Independent confirmation
vi. Computation and checks, sampling techniques
vii. Reliance on the work of other auditors, including statutory auditors
7. RISK BASED AUDIT APPROACH
i. Understanding Risk Based Auditing
ii. Focus of the risk-based audit
iii. Steps of risk based audit
• Determination of the threats (fraud and errors) confronting the organization
• Identification of control procedures for preventing, detecting or correcting threats
• Evaluation of control procedures – systems review and test of controls
• Determination of impact of control weaknesses and degree of auditing required
iv. The risk-based approach
• Taxpayer and Industry Profiling
CITN 2020 SYLLABUS Page 60
• Identifying specific compliance risks e.g. Low stock values compared to turnover;
International transfer pricing; Financing arrangements; Wrongly classifying capital
expenditure as deductions; etc.
v. Process of risk based audit approach
• Understand the Business Environment
• Develop a Three-year Audit Plan
• Preliminary Risk Assessment
• Secondary Risk Assessment
• Formal Exit Meeting
• Reporting and Communication
8. STATUTORY POWERS OF TAX AUDITORS AND INVESTIGATORS
i. Power to obtain information
ii. Power to enter premises
iii. Power to obtain third party confirmation from banks, etc
iv. Power of search and seizure under investigation
9. TAX AUDIT PROCEDURES AND RISK ASSESSMENT
i. Tax audit procedures and risk investigations
• Tax audit procedures on income ascertainment
• Tax audit procedures on expenditure ascertainment
• Tax audit procedures on VAT - Input and output tax including refunds
• Tax audit procedures on import duties
• Cost of Freight and Insurance (CIF) investigations
• Risk in stock taking
• Risk controls in sales department
ii. Sampling risk and forensic investigations
iii. Materiality concept and tax audit investigations
iv. Computer Assisted Audit Techniques (CAAT) relating to income and expenditure
RECOMMENDED TEXTS - TEXTBOOKS/JOURNALS AND OTHERS
Abdulrazaq, M. T. Principles and Practice of Tax Planning and Management in Nigeria
(Batay Law Publications)
Adeniji, A. A. (2016) Tax Audit & Investigation (Value Analysis Publishers)
Arogundade, J. A. Nigerian Income Tax and Its International Dimension
(Spectrum Books Limited), 2010
Bassey, O. U (2013) Companies Taxation in Nigeria (The CIBN Press Ltd)
CITN - Nigerian Tax Guide and Statutes
Fasoto, Foluso Nigerian Tax Companion (Hortosaf Associates Ltd)
CITN 2020 SYLLABUS Page 61
Kumar, R. & Sharma, V. (2011) Practical Auditing: A Risk-based Approach (PHI Learning Private
Limited)
Obatola O. S. (2018) Essentials of Tax Audit & Investigation. ASCO Publisher. Lagos
Ochei, B. B. The Nigerian Taxman’s Book
Olagbaiye, O. O. (2010) Auditing and Investigation (Alpha Resources Limited)
Oni, I. O. Nigerian Companies Income Tax: Law & Practice
Oyedokun G. E. (2017) Compendium of Writings in Forensic Accounting and Fraud
Examination (ASCO Publishers)
Oyedokun, G. E. (2018). Fundamentals of forensic accounting & fraud Investigation. Lagos,
Nigeria. Aaron & Hur Publishing.
Oyedokun, G. E. (2018). Ethical justification for creative accounting: Fraud & forensic
Accountants’ perspectives. Lagos, Nigeria. Aaron & Hur Publishing.
Oyedokun, G. E. (2019). Imperatives of tax audit & investigation. Lagos, Nigeria. Aaron & Hur
Publishing
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.
Vol. I &II
Offiong Bassey Tax Audit and Investigation: Revision Kit
CITN 2020 SYLLABUS Page 62
COURSE TITLE: INTERNATIONAL TAXATION Course Description
This course focuses on providing students with required knowledge on taxation law and policy from a comparative and
international view point. It covers principles of international tax law, tax policy, double tax treaties, transfer pricing rules
and thin capitalisation.
Prerequisite
Candidates taking the course should have knowledge of Principle of taxation, Income taxation, Business Law and
Economics.
Aims and Objectives of the Course:
At the end of this paper, the candidate should have the knowledge and understanding of the
following:
i. Basic principles of international tax law;
ii. How different domestic tax laws interact at the international plane;
iii. Causes of international double taxation;
iv. Tax implications on residence Rules;
v. Purpose of Double Taxation Treaty (DTT) and taxation of businesses, individual and investment income under
the DTT;
vi. Concept of Permanent establishment;
vii. Application of Nigerian transfer pricing regulation to related party transactions;
viii. Effect of Thin capitalization on income taxes;
ix. Tax planning strategies; and
x. The effects of offshore judicial decisions in resolving international tax matters in Nigeria.
COURSE CONTENTS
1. INTERNATIONAL TAX POLICY
i. Introduction to International taxation
ii. Objectives of international tax rules
iii. The need for, limitations and roles of international organisations
iv. The concept of tax neutrality
v. Taxation of inward and outward investments
vi. Definition of key terms
• Active and passive income distinction
• Portfolio investment
• Double taxation
• Source and residence tax jurisdiction
• Controlled Foreign Companies (CFC)
vii.Taxation and public international law
• History of international tax law
• Jurisdiction to tax including limits to tax jurisdiction arising from public international law
• Rules of public international law governing the assessment and collection of taxes; cross-border enforcement
of tax debts
• Introduction to international fiscal policy
• International settlement of fiscal disputes.
viii.International fiscal policy and income/profits taxation
CITN 2020 SYLLABUS Page 63
ix.Causes of international double taxation of income/profits
• Conflicts of residence and source
• Conflicting definitions of connecting factors
• Other causes of international double taxation (including particular issues for using citizenship as a
connecting factor for taxation
x. Methods of relief from international double taxation
• Relief by credit – including indirect/underlying credit and tax sparing credit
• Relief by exemption – including participation exemption
• Practical difficulties in applying relief by credit and relief by exemption
• Relief by exemption and relief by credit compared: capital import neutrality vs capital export neutrality
• Other methods of relief from international double taxation – relief by deduction of foreign tax; relief by
deferral
xi.International fiscal policy and indirect taxation
• Causes of international double taxation of indirect taxes: origin and destination bases of taxation
• Relief for international shipping and airlines • World Trade Organization (WTO), General agreement on tariffs and trade(GATT), General Agreement in
Trade in services (GAT) and their relevance to taxation.
xii.International co-operation between tax administrations
• International co-operation by bilateral agreement; analysis of model agreements on administrative co-
operation
• Multilateral co-operation between tax administrations
• Regional developments and cross-border co-operation, including regional economic integration and trade
blocs, African Continental Free Trade Area Agreement (AfCFTA), etc
2. RESIDENCE
i. General principles of jurisdiction
• in personam jurisdiction
• in rem jurisdiction
• general / unlimited jurisdiction on world-wide income / property
• limited jurisdiction on locally-sited or property or local-source income.
ii. Jurisdictional links for different taxes
• Customs duties
• Good and services taxes
• Estate and gift taxes
• income taxes
iii. The concept of connecting factors
• In persona connecting factors
- Nationality
- Residence
- Domicile
iv. Other in persona connecting factors – ordinary residence; habitual residence.
• In rem connecting factors
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- Situs
- Source -.
v. Individual residence
• State practice in determining residence of individuals:
- The 183-day rules
- Regular visitor rule e.g. business visit, 90+ days per year
- Definition of a day (24 hours or part of a day)
- Facts and circumstances of an individual’s life e.g. availability of home, Centre of individual’s life.
vi. Residence of corporations
• State practice in determining residence of corporations:
- Place of incorporation
- Place of central management and control
- Place of seat
- Place of head office
- Place of principal activity
vii. Residence of controlling shareholder(s).
• State practice in determining residence of other entities
viii. Partnerships – place of effective management
ix. Trusts – residence of trustees; place of effective management
x. Explain when a non-resident company is deemed to have significant economic presence in Nigeria.
xi. Discuss the requirement that a non-resident person that makes a taxable supply to Nigeria should
register for tax, include VAT on its invoice, and appoint a representative in Nigeria for the purpose of
its tax obligations.
xii. Explain when the profits on digital transactions rendered by non-resident companies will be deemed to
have been derived in Nigeria and taxed accordingly.
xiii. Explain when fees earned on transactions, such as technical, management, consultancy or professional
services rendered from abroad to a person in Nigeria will be taxable in Nigeria.
3. DOUBLE TAX TREATY (DTT)
i. DTT definition
ii. History of DTT
• The League of Nations
• The G20 and OECD
• The UN Group of Experts
iii. DTTs and domestic laws
iv. Purpose of DTT
• Avoidance of international double taxation
• Prevention of fiscal evasion, mutual agreement procedures, exchange of information and assistance in the
collection of taxes.
v. Stages in DTT
• Negotiating DTT
• Giving effect of DTT in domestic laws
• Commencement of DTT
• Termination of DTT
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vi. DTT FORMAT
• OECD Model and the Commentaries to the OECD Model
• UN MTC
• Specific states’ models: the US MTC; the Dutch MTC
vii. INTERPRETATION OF DTT
• General approach to interpretation
• The importance of the Vienna Convention on the Law of Treaties.
• The use of external aids for interpretation such as the status and use of the OECD Commentaries.
• The application of OECD MTC
• How interpretation issues are to be resolved by competent authority proceedings – OECD MTC.
• Commentaries on the relevant articles based on the Base Erosion and Profit Shifting Project by OECD and
the G20
viii. DTT PROVISIONS RELATING TO BUSINESSES
• Business profits (with or without a permanent establishment) – Art 7 OECD MTC
• Shipping and air transport profits – Art. 8 OECD MTC (in outline)
• Associated enterprises – Art. 9 OECD MTC: status of Art. 9 and link to transfer pricing legislation
ix. DTT PROVISIONS RELATING TO INDIVIDUALS
• Employment income – Art. 15 OECD MTC
• Pensions – Art. 18 OECD MTC
x. DTT PROVISIONS RELATING TO INVESTMENT INCOME AND GAINS
• Income from land – Art. 6 OECD MTC
• Dividends – Art. 10 OECD MTC –
• Interest – Art. 11 OECD MTC
• Royalties – Art. 12 OECD MTC
• Capital gains – Art. 13 OECD MTC
xi. RELEVANCE OF THE “OTHER INCOME” ARTICLE – ART. 21 OECD MTC
xii. LIMITATION OF BENEFIT PROVISIONS- BEPS ACTION 6 PROVISION OF TREATY ABUSE.
xiii. NIGERIAN DTT MODELS
• Nigerian Tax Treaties and Reliefs
• Typical clauses
• Treaty relief by credit
• Unilateral tax credit
• Reforms and planning
4 CONCEPT OF PERMANENT ESTABLISHMENT (PE)
i. Application of domestic laws
ii. The structure of the business profits provisions
• Overview of Arts. 5, 7, 8 and 9
• Relationship with the dividends etc. Arts. – Art. 7(7); 10(4), 11(4); 12(3); and capital gains Article 13.
iii. The permanent establishment concept
• The concept of a PE – sufficient presence in a host state
CITN 2020 SYLLABUS Page 66
• The structure of Art. 5 - The fixed place of business PE: paras. (1) – (2); the construction site PE: para. (3);
the exempt activities: para. (4); the dependent agent permanent establishment: paras. (5) – (6); associated
companies: para. (7); “associated” and “unassociated” permanent establishments
iv. The “fixed place of business” PE – The basic concept in Art. 5(1)
• The requirement of a place of business
• The requirement of being fixed.
v. The illustrative list in para. (2)
• What is the purpose of the illustrative list?
vi. The building site PE
• Is it a restriction on Art. 5(1)? – does it need to be equally fixed?
• When does the time period begin and end
• Linked contracts
• Use of sub-contractors.
vii. The exclusionary list: para. (4)
• Facilities or storage space
• Are the separate items all preparatory and auxiliary
• What does “preparatory and auxiliary” mean
• Combination of activities – (4)(f)
• Gathering information; representative offices.
viii. The dependent agent PE - Dependent agent: para. (5) Definition and different concepts of agency – common law
and civil law; common law: agent for an undisclosed principal; civil law courtiers and commissionaires
générales.
ix. Independent agents: para. (6) - Candidates should consider broker and general commission agent; other agent of
an independent status (independent legally and economically)
x. Associated companies - Candidates should also understand situations where subsidiaries would constitute a PE.
xi. OECD BEPS final report on preventing the artificial avoidance of PE status (Action 7).
xii. The provisions and application of the Income Tax (Country by Country Reporting) Regulations, 2018
• Purpose and objectives of the regulations
• Filing obligations and notification of tax residence of reporting entity
• Contents, form and time of filing of the Country- By- Country Report
• Non-compliance and penalties
5. CONCEPT OF TRANSFER PRICING AND NIGERIAN TAXATION
i. Overview of the Nigerian Transfer Pricing Regulations, including the purpose, objectives and scope of the
Income Tax (Transfer Pricing) Regulations, 2018
ii. Definition of Key terms
• Associate enterprise
• Controlled transactions/ covered
• Uncontrolled transaction
• Independent enterprise
• Arm’s length principle
• Connected taxable person
CITN 2020 SYLLABUS Page 67
iii. Specific transactions
iv. Transfer pricing methods
v. Advance pricing agreements (APA)
vi. Transfer pricing documentation
vii. Comparability factors
viii. Transfer pricing analysis
• Industry analysis
• Company analysis
• Functional analysis
• Economic Analysis
- Transfer pricing methods
- Bench marking analysis
ix. Procedure for tax dispute resolution under Transfer Pricing Regulations
x. Offences and penalties
xi. Other issues
6. EFFECTS OF OFFSHORE JUDICIAL DECISIONS
i. Judicial decisions on international tax matters
• The interpretation of the concept of beneficial ownership
• Resolving issues of dual residency for individuals and corporations
• Meaning of connecting factors
• Meaning of “liable to tax” and “subject to tax”
• Other relevant judgments on interpretation and application of DTT
7. THIN CAPITALISATION, TAX PLANNING ISSUES AND NIGERIAN TAXATION
i. Definitions
ii. Measures of addressing thin capitalisation
iii. Effects of thin capitalisation on taxes
iv. Limitation of interest on debt issued by a foreign connected person (excluding banks and insurance
companies) to a Nigerian company to 30% of earnings before interest, tax, depreciation and amortization
(EBITDA)
v. Treatment of excess interest not allowed for tax purposes in (iv) above
vi. Tax Havens
vii. Treaty Shopping
viii. Non-tax Factors
ix. Tax sparing agreements and foreign direct investments (FDI)
8. INTERNATIONAL TAX AVOIDANCE AND NIGERIAN TAXATION
i. Tax evasion and avoidance
ii. Tax avoidance and tax planning
iii. General principles of domestic laws
iv. Tax savings
v. Decided cases
RECOMMENDED TEXTBOOKS
Arogundade, J. A. - Nigerian Income Tax and Its International Dimension (Spectrum Books Limited)
CITN 2020 SYLLABUS Page 68
Van Raad, K. Materials on International, TP and EU Tax Law 2016-2017. Volume A (Leiden:
International Tax Centre, 2016).
Model Income Tax Convention, Analysis, Commentary by Van Raad, Kees
OECD. Base Erosion and Profit Shifting Project: 2015 Final Reports, Executive Summaries (Paris: OECD, 2015
OECD, Committee on Fiscal Affairs. Model Tax Convention on Income and on Capital (Paris: OECD,2010 [ISBN:
9789264089488
Qureshi, A. The Public International Law of Taxation: Text, Cases and Materials (London:
Kluwer Law International, 1994) [ISBN: 9781853339509
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017
United Nations. UN Practical Manual on Transfer Pricing for Developing Countries
Nigerian Income Tax Transfer Pricing Regulations
Federal Govt. Press - National Tax Policy
Fowokan, T. E. & Oyedokun, G. E. (2019). International Taxation in Nigeria. Lagos, Nigeria. Aaron & Hur Publishing
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.
Vol. I &II
CITN - Principles of International Taxation
CITN - Tax Incentives in a Globalised Economy
CITN - Tax Guide and Statutes
Offiong Bassey - International Taxation
CITN 2020 SYLLABUS Page 69
COURSE TITLE: FINANCIAL AND TAX
ANALYSIS
Aims and Objectives of the Course:
At the end of this course, candidates will be able to understand the followings:
i. Comprehensive framework for financial statement analysis and financial reporting;
ii. Important strategy points for the analysis of financial statements;
iii. The purpose of accounting analysis to evaluate the degree to which firm’s accounting is captured in
business reality;
iv. Ability to understand analysis required to adjust a firm’s accounting numbers using cash flow
information;
v. The assessment of performance of a firm in the context of its stated goals and strategy;
vi. To summarize the view developed in the analysis with an explicit forecast
vii. To understand forecasting at first and second stage of prospective analysis and valuation.
COURSE CONTENTS
1. FRAMEWORK FOR BUSINESS ANALYSIS AND VALUATION USING FINANCIAL
STATEMENTS
i. The role of Financial Reporting in Capital Markets
ii. From Business Activities to Financial Statements
iii. Influences of the Accounting System on Information Quality
iv. Alternative forms of Communication with Investors
v. Public versus Private Corporations
2. BUSINESS ANALYSIS AND VALUATION TOOLS
i. Industry Analysis
ii. Applying Industry Analysis
iii. Competitive Strategy Analysis
iv. Corporate Strategy Analysis
3. ACCOUNTING ANALYSIS: THE BASICS
i. Factors Influencing Accounting Quality
ii. Steps in Accounting Analysis
iii. Recasting Financial Statements
iv. Accounting Analysis Pitfalls
v. Value of Accounting Data and Accounting Analysis
4. ACCOUNTING ANALYSIS: ACCOUNTING ADJUSTMENT
i. Recognition of Assets
ii. Asset Distortions
iii. Recognition of Liabilities
iv. Liability Distortions
v. Equity Distortions
CITN 2020 SYLLABUS Page 70
5. FINANCIAL ANALYSIS
i. Ratio Analysis
ii. Cash Flow Analysis
iii. Trend Analysis
iv. Common Size Analysis
6. STRATEGIC TAX MANAGEMENT AND PLANNING
i. Introduction
• Definition of tax planning.
• Tax planning and management strategies.
• Taxation and present value analysis.
• Basic principles of tax planning.
• Factors affecting tax planning.
ii. Tax strategies for new business
• Organizational forms for business entities, corporate formation, partnership formation,
single proprietor formation. Basic tax consequences of entity choice.
• Sale or lease of property to controlled entities.
• Other strategies for transferring property to controlled entities.
iii. Employee compensation strategies
• Proprietor compensation, employee compensation, fringe benefits.
• Deferred compensation, equity-based compensation, employee stock plans/option.
• Partnership interest as payment for services.
iv. Taxation and business operating strategies
• Profit measurements and reporting.
• The entity’s accounting year, tax accounting methods.
• Differences (permanent and temporary) between book profit and taxable profit.
• Accounting for income taxes: deferred tax assets and liabilities, corporate tax payment
requirements.
v. Tax incentive provisions:
• Tax incentives and after-tax business value, criticisms of tax incentives; and
• Restrictions on their benefits.
vi. Tax implications of profit distributions - corporate, partnership and sole proprietorship.
vii. Tax implications of Anti-Avoidance Schemes.
viii. Taxation and Capital Marketing Activities.
ix. Tax planning and management, using holding companies and group structures;
x. Tax implications and tax management in mergers and acquisition of business entities.
xi. Tax planning through the use of derivative instruments.
xii. Tax considerations and tax planning in intellectual properties management.
CITN 2020 SYLLABUS Page 71
RECOMMENDED TEXT
Krishna, G. P., Paul, M., H., and Erik P., (2013). Business Analysis and Valuation: IFRS Edition;
Andrew Ashwin.
Kintoye I.R. (2016) -Investment Decisions in the 21st Century (Unique Educational Publishers.
Olowe, R. A. (2017). Financial management: Concepts, financial system and business finance. Fourth
Edition. Published by Brierly Jones Nigeria Limited, Lagos State.
CITN Tax Guide and Statutes
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.
Vol. I &II
COURSE TITLE:
CITN 2020 SYLLABUS Page 72
INCOME TAX FOR SPECIALISED BUSINESSES
AND PROCESSES
Course Description:
The course introduces students to the peculiarities of specialised businesses and the specific tax rules that
guide the imposition of income tax on the profits of companies involved in these businesses.
Pre-Requisite:
Students taking this course must have knowledge of the following courses:
• Principles of Taxation;
• Income Taxation; and
• Financial Reporting.
Aims and Objectives of the Course:
At the end of this paper, the candidate should have the knowledge and understanding of the
following:
i. Understand the various specialized businesses and situations which demand a shift in the general
knowledge of income taxation previously studied;
ii. Understand the operations of the specialised businesses of Banking, Insurance, Oil and Gas,
Agriculture, Airlines and Shipping, Mining of Solid Minerals, Unit Trust, Real Estate Investment
Companies (REIC) and Regulated Securities Lending Transaction (‘SEC Lending’);.
iii. Discuss the specific accounting recognition requirements for revenue and expenses for these
businesses;
iv. Understand the specific provisions of the income tax laws that guide the taxation of these businesses
separately from other non-specialised businesses;
v. Understand how these special provisions are applied in practice and any other practical tax issue
impacting these businesses; and
vi. Understand the application of the income tax provisions to companies under pioneer status as well as
operating within the free trade zone.
COURSE CONTENTS
1. TAXATION OF BANKS AND OTHER FINANCIAL INSTITUTIONS (BOFI)
i. Discuss the requirement that banks should obtain the Tax Identification Number (TIN) of new and
existing business customers.
ii. Discuss the VAT exemption of services rendered by microfinance banks.
iii. Discuss the requirement that banks should submit within seven days after the end of each month, the
names and addresses of new customers in respect of the preceding month, to FIRS.
CITN 2020 SYLLABUS Page 73
iv. Discuss the requirements that banks should file both monthly and annual tax returns, and the penalties
for failure to file such returns.
v. Explain the concept of revenue recognition for BOFI and the various types of revenue viz interest
income, commission, sale of financial instruments, financial intermediation etc.
vi. Determine which of the streams of income would qualify as revenue and or other income under the
relevant accounting standards – Specifically International Financial Reporting Standard (IFRS 15).
vii. Explain the accounting treatment of hedging transactions and discuss its income tax implications
viii. Define and explain the various financing arrangements and loan relationships engaged in by BOFI
including but not restricted to syndicated loans and sale and lease back arrangements
ix. Discuss the CIT exemption order for the exemption of short-term securities, bonds, Section 23(l) of the
CITA etc. and their impact on the taxation of BOFI.
x. Differentiate between income earned in the ordinary course of business and income earned outside the
ordinary course of business, i.e., sale of shares by a company and the sale of shares by a brokerage
company.
xi. Compute the assessable profit, total profit and taxes payable.
xii. Contemporary issues, such as the impact of Section 19 on Banks whose major source of income is
exempted from income tax, amongst others.
2. TAXATION OF INSURANCE COMPANIES
i. Distinguish between the two types of insurance business types (General and Life) and identify their
characteristics.
ii. Identity and understand key terms which include: unexpired risks, claims, outgoings, gross
premium interest, reinsurance expense, investment income, actuarial revaluation certificate,
underwriting profits, premium, total premium, total profits and fees etc.
iii. Explain investment income for life insurance business based on Finance Act, 2019.
iv. Explain the definitions of gross income for minimum tax purposes for non-life and life insurance
businesses based on Finance Act, 2020.
v. Identify and understand what constitute income for both types of businesses
vi. Understand the requirement to separate the reporting and tax computation for both types of
businesses, using the new formats based on the Finance Act, 2019 and Finance Act, 2020
vii. Discuss the scope and charging provision in respect of income tax for both businesses.
viii. Understand the new provision that the reserve for un-expired risk should be based on a time
apportionment basis of the risk accepted in the year
ix. Understand the new amendment which allows for estimated amount of outstanding claims and
outgoings instead of an amount based on a percentage of total premium
x. Understand the tax treatment of estimated claims and outgoings made in one year and the
adjustment in the year following
xi. Understand the limitation on certain allowable deductions and treatment of other allowable
deductions and earned investment income for life businesses
xii. Understand the new provision on non- restriction of loss carried forward.
xiii. Computation of companies income tax payable
xiv. Computation of minimum tax based on Finance Act, 2019 and Finance Act, 2020
CITN 2020 SYLLABUS Page 74
xv. Explain and understand the provisions on the deduction of general reserve fund for re-insurance
companies.
xvi. Disclosure requirements for insurance companies that engage the services of an insurance agent, a
loss adjuster or an insurance broker.
xvii. Understand the requirement that a non-life insurance company should maintain details and
schedules of policies or risks accepted in a given year, and the computation of un-expired risks
associated with them
xviii. Contemporary tax issues
3. TAXATION OF UNIT TRUSTS
i. Description and objectives of a unit trust scheme
ii. Legal basis for the taxation of unit trusts – Section 17 of the CITA
iii. Definition of key terms with particular reference trustees; unit holders; rights of unit holders;
dividends; authorized unit trusts; etc.
iv. Determination of the profits of a unit trust scheme and treatment of deductions suffered by unit trust
schemes
v. Applicability of provisions on dividends payment to profits accruing to trustees of unit trusts and
tax-exemption (and otherwise) of dividends distributed by unit trusts
vi. Withholding tax obligations for Unit Trust Schemes
vii. Filing and payment requirements for unit trusts
viii. Contemporary tax issues, such as tax transparency of the Unit trust system.
4. MINING OF SOLID MINERALS
i. Overview of the Mining Industry in Nigeria including list of solid minerals available in Nigeria and
their areas of concentration; types of mining licenses and process of obtaining a mining license.
ii. Tax Incentives available to Companies involved in the Mining of Solid Minerals in Nigeria including,
income tax reliefs, accelerated capital allowances etc.
iii. Treatment of decommissioning costs
iv. Allowable and disallowable expenses
v. Treatment of losses
vi. Computation of capital allowances
vii. Computation of total profits
viii. Offences and penalties
ix. Contemporary tax issues
7. TAXATION OF AIR/SHIPPING/CABLE UNDERTAKING BUSINESS
i. Definition and examples of Air/Shipping Transport Business and Cable undertakings and their
peculiarities.
ii. Explanation of key terms as defined under Sections 14 and 15 of the CITA.
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iii. Explanation of the meaning of a Nigerian Company and non-Nigerian Company
iv. Procedure for determining profits derived from Nigeria and explanation of the concept of
proportional profits
v. Conditions for accepting proportional profits, calculation of adjusted profits and adjusted
depreciation ratios
vi. Explanation of “fair percentage” as mentioned in the relevant provisions and related conditions
(students should be aware of the applicable procedures for objections and appeal)
vii. Minimum tax provision for these natures of businesses
viii. Provisions of the Double Tax Treaty on Air/Shipping Transport Business and Cable undertakings.
ix. Contemporary tax issues such as the application of the Provisions of the Nigerian Information
Technology Development Agency Act (NITDA) 2007
8. TAXATION OF AGRICULTURAL BUSINESS
i. Definitions of agricultural business and primary agricultural production
ii. Legal Basis for the taxation of agricultural business
iii. Conditions to be met before the interest on any loan granted by a bank to a company engaged in
primary agricultural production can be exempted from tax
iv. Computation of Capital Allowances (CA) computation for agricultural business and non-restriction
of capital allowances including enhanced capital allowance for agro-allied plant and equipment.
v. Double tax treaty (DTT) provisions on immovable properties and its application to agriculture and
forestry.
vi. Practical income tax computations for agricultural businesses
vii. Grant of pioneer status for a small or medium company engaged in primary agricultural production
for an initial period of 4 years and an additional 2 years.
9. TAXATION OF OIL EXPLORATION AND PRODUCTION COMPANIES
i. Overview of the Oil and Gas Industry in Nigeria, delineating which activities fall under upstream,
midstream, downstream, gas utilization and Oil service sectors
ii. Outline the basic roles of the Regulatory agencies in the oil and gas sectors, such as the NNPC,
NAPIMS, NIPEX, DPR, CBN, FIRS, NCDMB
iii. Understanding the applicable legislation for the various activities in the Oil and Gas Industry and the
form of income tax payable.
iv. Definition of Petroleum Operations based on the Petroleum Profits Tax Act (PPTA).
v. Definition of Key Terms in the Upstream Sector
vi. Description of the various fiscal/operating arrangements for upstream petroleum operations (i.e. Sole
Risk Operation, Risk Service Contracts, Joint Ventures, Production Sharing Contracts, taking into
consideration the provisions of the Deep Offshore and Inland Basin Production Sharing Contract
(Amendment) Act, 2019, and Marginal Field Operators etc.) and whether participants will qualify as
engaged in Petroleum operations as defined under the PPTA.
vii. Understand what constitutes accounting period for Petroleum Profit Tax (PPT) purposes and the basis
of assessment.
viii. Determine and understand the sources of income accruing to oil and gas (upstream) companies
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ix. Treatment of gas profits and analysis of gas production incentives.
x. Definition and basis for the computation of adjusted profit, assessable profit, chargeable profit and
petroleum profit tax
xi. Basis for treating expenses as tax-deductible or otherwise for PPT purpose including a summary of
specific deductible and non-deductible expenses
xii. Peculiarities of PPT computations vis-à-vis CIT computations – Treatment of Balancing
Charge/Allowance, Tertiary Education Tax, NDDC Levy, Royalties.
xiii. Description of qualifying capital expenditure for capital allowance purpose and compute capital
allowance/petroleum investment allowance claimable by petroleum companies.
xiv. Treatment of losses for E&P companies
xv. Differing PPT and royalty rates and their bases
xvi. Incentives available to companies that signed PSC agreement with the Federal government of
Nigeria
xvii. Offences and applicable penalties to petroleum companies
xviii. Registration, reporting and payment requirements for petroleum companies
xix. Implications for the sale of license vs sale of shares, regulatory approval and applicability of
transaction taxes.
xx. Contemporary tax issues which include:
• Treatment of abandonment/decommissioning costs
• Unitization agreements
• Back-in-rights
• Interest on intercompany loans
• Community expenses
• Gas banking
• Joint filing of PPT returns
• Dividends from gas business
xxi. Review of case laws
10. MERGERS, ACQUISITIONS, TAKEOVERS AND RESTRUCTURING
i. Description of mergers (including the various types), takeovers, acquisition and restructuring
ii. Legal Basis for the tax treatment for the various option
iii. Benefits of mergers, acquisitions, takeovers and restructuring
iv. Understanding of the issues to consider before mergers, acquisition etc. (e.g. filing of returns, payment
of outstanding tax liabilities, tax queries or audits, availability of tax clearance certificates.
v. Possible tax incentives/planning options during mergers, acquisitions and takeovers
vi. Treatment of capital allowance and tax-written down value of assets after mergers, takeovers, acquisition
and restructuring
vii. Exemptions of assets sold or transferred in business reorganization and restructuring from VAT and CGT
viii. Application of the relevant rules (i.e., Commencement, change of accounting date and cessation rules)
post mergers, takeovers, acquisition and restructuring
ix. Conditions that must be met by any entity before the tax concessions stated in (vi) above are granted
11. INDUSTRIAL DEVELOPMENT (PIONEER LEGISLATION)
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i. Define the relevant terms.
ii. Explain the key roles of the arms of government that are involved in the formulation, approval and
administration of the pioneer status incentive (PSI).
iii. Identify various pioneer industries and products, on the pioneer list.
iv. Explain the conditions that must be met by an applicant before it is granted pioneer status.
v. Enumerate and understand the tax incentives available to pioneer companies (tax exemption, treatment
of loss incurred during pioneer period; treatment of asset acquired during the period etc)
vi. Explain the procedure for applying and obtaining pioneer status and how pioneer certificate can be
amended, taking into consideration the application guidelines for pioneer status incentive issued by
Federal Ministry of Trade and Industries in 2017.
vii. Explain how a project presentation to Nigerian Investment Promotion Commission (NIPC) is carried
out.
viii. Explain the contents of application forms for new and extension PSI applications.
ix. Explain the procedure for carrying out due diligence visits by NIPC staff.
x. Explain the procedure for the submission of annual performance report to NIPC for monitoring and
evaluation purposes.
xi. Explain the payment of fees by applicants.
xii. Explain the periodic impact assessment to be carried out by NIPC staff.
xiii. Explain compliance with the Industrial Development (Income Tax Relief) Act, No 22 of 1971 (“IDA”)
and application guidelines for PSI.
xiv. Understand the provisions relating to retrospective operations and the date of production certification
xv. Understand the conditions for Qualifying capital expenditure for a pioneer company
xvi. Circumstances for cancellation, information and publication of pioneer certificate
xvii. Tax relief period and the conditions for extension of the period by the National council of ministers
xviii. With copious examples, explain the application of the commencement and cessation provision to pre
and post pioneer businesses, together with the treatment of losses and capital allowance of pioneer
period
xix. Applicable restrictions to pioneer companies
xx. Explain the offences and penalties.
xxi. Contemporary tax issues
12. EXPORT/FREE TRADE ZONE BUSINESS
i. Definition of Free Zones and list at least 10 examples in Nigeria
ii. Legal framework for the operation of Free Zones in Nigeria
iii. Administration of the Free Trade Zone
iv. Procedures for registering companies in the Free Zone and relevant reporting requirements
v. The fiscal benefits/incentives for operating in a Free Zone
vi. Specific tax implications of operating in a Free Zone which may also include transaction taxes such
as value Added Tax and Withholding tax (WHT).
vii. Compliance with filing of tax returns to the FIRS as a condition precedent to enjoy tax exemption by
companies operating in the zone
viii. Contemporary tax issues
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7. REAL ESTATE INVESTMENT COMPANIES (REIC)
i. Definitions
ii Relevant regulatory provisions
iii Explanation of the nature of business of real estate investment scheme (REIS)
iv Types of income of REIC
v Taxation of fees and other income, and gains from disposal of assets
vi Exemption of dividend and rental income received by a REIC from tax [section 23(1) of CITA (as
amended)]
vii Non-deduction of WHT from any distribution or dividend payment to a REIC pursuant to a REIS
viii Deduction of WHT of 10% on a distribution or dividend payment to shareholders and remittance
of same to the relevant tax authorities
8. REGULATED SECURITIES LENDING TRANSACTIONS (‘SEC LENDING’) IN NIGERIA
i Definitions
ii Relevant regulatory provisions
iii Explanation of regulated securities lending transactions (‘SEC lending’) in Nigeria
iv Types of income under a SEC lending
v Taxation, exemptions and concessions on the income arising from SEC lending transactions under CITA
vi Taxation on income earned by an individual under a SEC lending
vii Documents and transactions under a SEC lending that are exempt from stamp duties
RECOMMENDED TEXTS
Adesola, S. M. - Income Tax Law and Administration in Nigeria (O. A. U. Press)
Abdulrazaq, M. T. - Nigerian Tax Offences and Penalties (Batay Law Publications)
Oni, I. O. - Nigerian Companies Income Tax: Law & Practice
CITN - Tax Guide andStatutes
Teju Somorin - TejuTax Reference Book. Malthouse Press Limited, 2012 Edition.
Vol. I &II
Offiong Bassey - Income Taxation
Offiong Bassey -Personal Income Tax